International Cross Border Transactions
Author: Allison McLeod
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC |
Join Allison McLeod, CPA, for an introductory course in international cross border transactions. We will discuss typical situations in which a cross-border transaction arises, and how a taxpayer can utilize the rules to potentially decrease an entities effective tax rate. Other issues, such as documentation and IRS audit risk will also be covered. These rules will be illustrated by a hypothetical US-Canada transaction.
Publication Date: August 2019
Designed For
Ideal for CPAs, EAs and other tax preparers.
Topics Covered
- U.S. Entity with Foreign Operations
- Foreign Corporations with Us Operations
- Royalties and License Fees
- Minimizing Effective Tax Rate
- Inversions
- Cross Border Financing
- Resolving Conflicts
- Case Study- Caterpillar
Learning Objectives
- Identify a cross border transaction and be able to discuss potential implications
- Describe potential audit risks involved with cross border transactions
- Recognize how to explain the role of competent authority, advanced pricing agreements and other alternative methods in reducing audit risk
- Identify the types of contemporaneous documentation needed
- Recognize and apply these principles in order to decrease and entity's effective tax rate
- Recognize which income streams will be taxed by the U.S.
- Identify which type of agreement can be used so that the taxing authorities can agree on the allocation of profit to their various jurisdictions
- Recognize what is not a conduit by which a U.S. Corporation can conduct business in a foreign country
- Describe the withholding rate for dividends paid by the U.S. to a foreign parent
- Differentiate tax concepts which would not prevent a transaction and other types of uncontrolled income shifting
- Describe inversion
- Identify which type of action by a taxpayer Section 168(j) earnings stripping rules are designed to prevent
- Recognize false statements about the current audit environment for transfer pricing issues
- Identify what options a taxpayer have when two different taxing authorities are auditing the same cross-border transaction
- Describe methods a taxpayer can use to resolve controversy between two taxing authorities auditing the same transaction
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
