Description
An overview of the U.S. tax treaty definitions and their impact on permanent establishment, business profits, tax residency, hybrid entities and more.
Objectives
- Identify when a permanent establishment exists
- Determine the attributable business profits to a permanent establishment
- Recall how U.S. tax treaties determine U.S. tax residency and how it impacts eligibility under the treaty
- Distinguish how hybrid entities are treated under U.S. income tax treaties
- Determine the impact a US income tax treaty has on withholding taxes on FDAP
- Apply the appropriate LOB clause to determine eligibility under a U.S. tax treaty
- Identify the mechanisms for tax dispute resolution
Highlights
- Permanent establishment
- Business profits
- Tax residency
- Hybrid entities
- FDAP income
- LOB clauses
- Income resourcing
- Foreign tax credits