U.S. Source Withholding Tax Rules and Tax Treaty Application (Currently Unavailable)

Author: Adnan Islam

Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2024 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

This course will cover a discussion of the U.S. withholding tax rules under Chapter 3 (FDAP) of the Internal Revenue Code (IRC), corresponding IRS forms/compliance relating to withholding tax on FDAP, and (Income) Tax Treaty Application (e.g., DTT/Convention).

Publication Date: November 2021

Designed For
Experienced tax staff through tax director level interested in or already practicing U.S. international income taxation.

Topics Covered

• What are the fundamental U.S. withholding tax rules under Chapter 3 of the IRC?
• What is FDAP?
• What are the basic IRS compliance and potential documentation requirements for U.S. withholding taxation under Chapter 3 of the IRC?
• Tax treaty application and mitigation of the statutory U.S. withholding tax rate

Learning Objectives

• Identify the Chapter 3 U.S. withholding tax rules
• Recognize items of FDAP income
• Recognize IRS forms, compliance, and/or documentation that may be required to report and comply with the U.S. withholding tax rules under Chapter 3 of the IRC
• Recognize that U.S. has income tax treaties (e.g., DTTs or Conventions) with many countries, and applicable treaties may mitigate or eliminate the statutory rate of U.S. source withholding
• Identify the percentage the payer must backup withold if a receipent does not provide Form W-9 and is not exempt
• Identify the first step in how a treaty becomes a law
• Recognize what applies if a person is determined not to be a resident of either country under each country's respective tax laws

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Read IRC Sections 871, 881, 1441, and 1461. Read Form 1042-S Instructions.

Advance Preparation
None