Covers effectively connected income (ECI), branch profits tax (BPT), branch level interest tax, and 1120-F with treaty-based form compliance in more detail with computational examples.
Learning Objectives
Identify the existence of a U.S. trade or business;Calculate ECI of the U.S. trade or business;Calculate BPT and branch level interest;Determine what forms and schedules are needed for Inbound U.S. tax compliance;Determine the characterization of the income stream;Apply the appropriate sourcing rule to a particular income stream;Determining when a payment is considered FDAP;Identify how tax treaties impacts rate of withholding;Recall the FATCA definitions, documentation requirements, and associated requirements;Identify the associated U.S. withholding tax compliance on FDAP and ECI;Identify a USRPI and a USRPHC;Determine when FIRPTA applies and does not apply;Identify the FIRPTA withholding and notification requirements;Determine when the FIRPTA applicability and withholding exceptions apply
Major Topics
Cover sourcing;WHT rules;FATCA, and compliance
