Fundamentals of Inbound US Rules of International Taxation 2023

The United States loves to tax the U.S.-source income of foreign individuals and businesses. This program will cover the U.S. taxation of their pas...

6/5/2023 10:00am - 1:30pm | Online | CalCPA

Members: $159.00, Non-members: $209.00

CPE Categories: Taxation (4 CPE)

Interest Areas: Business Taxation

Description

The United States loves to tax the U.S.-source income of foreign individuals and businesses. This program will cover the U.S. taxation of their passive and business income (and how tax treaties impact that taxation) before diving into the transfer pricing rules.

Presented by Robert Misey

Target Audience

CPAs and tax professionals that work with international tax issues.

Course Objectives

Identify issues with respect to cross border transactions
Determine when the income is subject to the U.S. tax net
Recognize opportunities for tax minimization strategies

Subjects

Withholding on dividends, interest, rents, royalties, and compensation
Withholding rules on foreign investment in U.S. Real Estate
163(j) and Base Erosion Anti-abuse Tax restrictions on repatriation
Foreign Persons with a U.S. Trade or Business
Taking advantage of tax treaties
Tax-Advantaged Transfer Pricing
IRS Audit Tools for Foreign-Owned Corporations