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 U.S. taxation of cross-border transactions, focusing on taxation of foreigners investing in the U.S. Topics will cover: 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.
Income tax treaties. Residence tests. Effectively connected income. FDAP and FIRPTA withholding. Avoiding transfer taxation of foreign investors. Pre-immigration tax planning.
Completion of an introductory course on international taxation or working knowledge of international tax rules.
Accountants, business managers and CFOs.
Identify tax issues present in cross-border business transactions and investments. Determine how to plan for and around international tax issues.
Jacob Stein, California CPA Education Foundation
Jacob Stein, Esq. is a partner with the law firm Klueger and Stein, LLP, in Los Angeles, California. The firm’s practice is limited to asset protection, domestic and international tax planning, and structuring complex business transactions.
Mr. Stein received his law degree from the University of Southern California, and his Master’s of Law in Taxation from Georgetown University. He has been accredited by the State Bar of California as a Certified Tax Law Specialist and is AV-rated (highest possible rating) by Martindale-Hubbell.
Mr. Stein is an author of numerous tax and asset protection articles and technical manuals and a frequent lecturer to various attorney, CPA and other professional groups. He is an adjunct professor of taxation at the CSU, Northridge Graduate Tax Program.
Non-Member Price $119.00
Member Price $89.00