International Cross Border Transactions

Overview

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.

Prerequisites

None

Objectives

• 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.

Highlights

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