International Cross Border Transactions
Author: Allison McLeod
| CPE Credit: |
2 hours for CPAs 2 hours Federal Tax Related for EAs and OTRPs 2 hours Federal Tax Law for CTEC |
Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2028 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
Join us for an introductory course in international cross border transactions. We will discuss typical situations in which a cross-border transaction arises, and how a taxpayer can utilize the rules to potentially decrease an entities effective tax rate. Other issues, such as documentation and IRS audit risk will also be covered. These rules will be illustrated by a hypothetical US-Canada transaction.
Publication Date: October 2025
Topics Covered
- Use of Inversions to Reduce the Effective Tax Rate
- Effect of Cross Border Financing in Shifting Income and Deductions
- Resolving Conflicts Between Jurisdictions
- Cross Border Case Studies
- Branch Profits Tax
- Effect of Transferring Abroad Intellectual Property
Learning Objectives
- Understand and discuss the implications of cross border transaction
- Assess possible exposure issues with profit allocation among different jurisdictions involved in manufacturing, sales or the provision of services
- Understand the different options in resolving transfer pricing controversies, including the use competent authority, advanced pricing agreements and other alternative methods
- Determine how to use cross-border transactions to potentially reduce a business’ effective tax rate
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None