Description
The tax consequences of a cross-border transaction can make or break any deal-and CPAs must know the basics and be aware of the traps. Get an introduction to the US taxation of cross-border transactions, focusing on taxation of foreigners investing in the US. Topics will cover: the basics of tax treaties, residency tests, effectively connected income, FDAP withholding, FIRPTA withholding, branch profits tax, ownership structures for non-resident aliens, gift and estate tax planning for foreign investors and pre-immigration income and estate tax planning. Limited discussion of taxation of outbound transactions, focusing on CFCs.
Presenters - Jacob Stein
Designed For
Designed For: Accountants, business managers and CFOs.
Role Level - Entry-level/Individual contributor; Manager/Senior Manager; Director; Sole Practitioner
Objectives
- Identify tax issues present in cross-border business transactions and investments
- Determine how to plan for and around international tax issues
Highlights
- Income tax treaties
- Residence tests
- Effectively connected income
- FDAP and FIRPTA withholding
- Avoiding transfer taxation of foreign investors
- Pre-immigration tax planning
Advanced Prep
None
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Leaders
CALCPE Panel
No Biography Available