Description:

Please join us 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.

Learning Objectives:

After attending the presentation you will be able to...

• Identify a cross border transaction and be able to discuss potential implications.
• Determine potential audit risks involved with cross border transactions.
• Explain the role of competent authority, advanced pricing agreements and other alternative methods in reducing audit risk.
• Understand the types of contemporaneous documentation needed.
• Apply these principles in order to decrease and entity’s effective tax rate.

Program Content:

The major topics that will be covered in this class include:

• Branch Profits Tax
• Controlled Foreign Corporations
• Transfer of Intangibles
• Effective Tax Rates
• World-wide Taxation
• Territorial Taxation

Who should attend: This course is suitable for Corporate tax and finance executives, directors, managers and staff, CPAs, CAs Enrolled Agents, accountants, attorneys and business/financial advisors who work with and advise businesses that have cross-border operations and issues.

Developed By: Allison M. McLeod, LL.M., CPA. A PLLC

Instructor: Allison M. McLeod

CPE Credit: 2.0

Field of Study: Taxes (2 CPE)

Prerequisites: None

Advanced Preparation: None

Format: QAS Self Study