On-Demand


13.5 CPE

U.S. International Tax: Advanced Issues (On-Demand) 2022

On-Demand
13.5 CPE

Learning Objectives

  • Identify the accepted transfer pricing methods and when it’s appropriate to use them
  • Recall how U.S. tax treaties determine U.S. tax residency and how it impacts eligibility under the treaty
  • Distinguish how hybrid entities are treated under U.S. income tax treaties
  • Assess whether a U.S. person’s transfer of property to a foreign corporation should generally qualify for non-recognition treatment under section 351
  • Assess whether a reorganization or restructuring may qualify as an “inversion” subject to the rules of section 7874

Major Topics

  • Section 351
  • Transfer Pricing
  • Permanent establishment
  • Tax Treaties
  • BEPS overview
  • Reorganizations
  • Stock acquisitions
  • Corporate formation
  • Inversions

CPE Credits Available

13.5 CPE
13.5
Taxes

Things to Know About This Course

Course Level

  • Basic

Prerequisites

None

Intended Audience

Public and corporate tax professionals.

This can not be purchased at this time.