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.
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.
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.
- Robert Misey Jr
Non-Member Price $209.00
Member Price $159.00