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.
Learning Objectives
• Identify tax issues present in cross-border business transactions and investments
• Determine how to plan for and around international tax issues
Major Topics
• Income tax treaties
• Residence tests
• Effectively connected income
• FDAP and FIRPTA withholding
• Avoiding transfer taxation of foreign investors
• Pre-immigration tax planning
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