International Tax Treaties

Author: Allison McLeod

This on-demand course presents an overview of tax treaties and how they are used in structuring transactions and determining the tax impact of cross-border transactions. It discusses the ordering rules for local laws versus treaty laws, and the purpose of the tax treaties in avoiding and eliminating double taxation to promote trade and investment. The participant will learn about planning opportunities to contemplate when structuring foreign operations.

Publication Date: August 2019

Designed For
Corporate tax and finance executives, directors, managers and staff, CPAs, CAs Enrolled Agents, accountants, attorneys and business/financial advisors who wor kwith and advise businesses that have cross-border operations and issues. All in-house and public practice professionals involved with international tax compliance and planning will benefit from this timely and insightful seminar.

Topics Covered

• Background
• Permanent Establishment
• Researching Treaties
• Interpreting Treaty Provisions
• Common Treaty Provisions
• Resolving Conflicts
• Limitation on Benefits
• Select Compliance Issues

Learning Objectives

• Recognize a better understanding of the international tax environment
• Describe the purpose of income tax treaties in the tax regimes of countries
• Recognize qualifications for a permanent establishment
• Identify how to discuss common treaty provisions in the US Model Treaty
• Identify typical reduced withholding rates on dividends, interest, and royalties
• Describe the rules by which a taxpayer must disclose a tax position to the IRS for claimed treaty benefits that is in conflict with the IRC
• Recognize ascertain mutual agreement procedures between the taxing authorities of two treaty countries in cases of double taxation
• Recognize when a company/citizen would need to file Form W8”BEN with the IRS in order to claim treaty benefits for US tax withholding
• Identify good sources for researching treaties
• Recognize which U.S. tax form is used if taxpayer is claiming treaty benefits that overrides the IRC
• Identify what income tax treaties seek to accomplishes
• Describe a permanent establishment
• Describe dispute resolutions
• Differentiate the tests that can prove the ways a foreign entity can prove its benefits under the treaty
• Recognize the process of utilizing tax treaties that best interprets the process
• Identify the penalty for not filing Form 8833
• Describe Form1040NR

Level
Basic

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None