The United States loves to tax the US 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.
Learning Objectives
• Identify issues with respect to cross-border transactions
• Determine when the income is subject to the US tax net
• Recognize opportunities for tax minimization strategies
Major Topics
• Withholding on dividends, interest, rents, royalties, and compensation
• Withholding rules on foreign investment in US Real Estate
• 163(j) and Base Erosion Anti-abuse Tax restrictions on repatriation
• Foreign Persons with a US Trade or Business
• Taking advantage of tax treaties
• Tax-Advantaged Transfer Pricing
• IRS Audit Tools for Foreign-Owned Corporations
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