International Taxation 2024

Overview

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 US taxation of cross-border transactions, focusing on taxation of foreigners investing in the US. Topics will cover: the 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.

Highlights

• Income tax treaties
• Residence tests
• Effectively connected income
• FDAP and FIRPTA withholding
• Avoiding transfer taxation of foreign investors
• Pre-immigration tax planning

Prerequisites

Completion of an introductory course on international taxation or working knowledge of international tax rules.

Designed For

Accountants, business managers and CFOs.

Objectives

• Identify tax issues present in cross-border business transactions and investments
• Determine how to plan for and around international tax issues

Preparation

None

Notice

This course is provided by a third-party vendor. Please note that login instructions will not be available in the ‘My Upcoming CPE’ section of the NESCPA website. Instead, the login instructions will be sent directly to you via email by the California Education Foundation (CalCPA). Upon completing the course, your hours will be recorded in the ‘My CPE Tracker’ section of the NESCPA website.