Description
Covers effectively connected income (ECI), branch profits tax (BPT), branch level interest tax, and 1120-F with treaty-based form compliance in more detail with computational examples.
Designed For
- Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.
Objectives
- Identify the existence of a U.S. trade or business
- Calculate ECI of the U.S. trade or business
- Calculate BPT and branch level interest
- Determine what forms and schedules are needed for Inbound U.S. tax compliance
- Determine the characterization of the income stream
- Apply the appropriate sourcing rule to a particular income stream
- Determining when a payment is considered FDAP
- Identify how tax treaties impacts rate of withholding
- Recall the FATCA definitions, documentation requirements, and associated requirements
- Identify the associated U.S. withholding tax compliance on FDAP and ECI
- Identify a USRPI and a USRPHC
- Determine when FIRPTA applies and does not apply
- Identify the FIRPTA withholding and notification requirements
- Determine when the FIRPTA applicability and withholding exceptions apply
Highlights
- Cover sourcing
- WHT rules
- FATCA, and compliance