Fundamentals of Inbound US Rules of International Taxation 2024
4.00 Credits
Member Price $159
Non-Member Price $209
Overview
The United States loves to tax the US source income of foreign individuals and businesses. This program will cover the U.S. taxation of their passive and business income (and how tax treaties impact that taxation) before diving into the transfer pricing rules.
Highlights
- Withholding on dividends, interest, rents, royalties, and compensation
- Withholding rules on foreign investment in US Real Estate
- 163(j) and Base Erosion Anti-abuse Tax restrictions on repatriation
- Foreign Persons with a US Trade or Business
- Taking advantage of tax treaties
- Tax-Advantaged Transfer Pricing
- IRS Audit Tools for Foreign-Owned Corporations
Prerequisites
None
Designed For
CPAs and tax professionals that work with international tax issues.
Objectives
- Identify issues with respect to cross-border transactions
- Determine when the income is subject to the US tax net
- Recognize opportunities for tax minimization strategies
Preparation
None
Leader(s):
Leader Bios
Robert Misey Jr., CalCPA Education Foundation
Robert Misey is a shareholder with Reinhart Boerner Van Deuren s.c. He practices in the areas of international taxation and tax controversies. His previous experience includes nine years as an international trial attorney for the IRS in San Jose and in Washington, DC where he tried 21 Tax Court cases and served on the industry programs for both the athletics and entertainment industries and the manufacturing industries. He also led the international tax group for a region of a Big Four accounting firm. Misey received his bachelor’s degree from the University of Kentucky, his juris doctor and master of business degrees from Vanderbilt University, and his master of laws in taxation from Georgetown University. He is a co-author to the treatises U.S. Taxation of International Transactions and Federal Taxation: Practice and Procedure, and a member of the bar in California, Kentucky and the District of Columbia.
Non-Member Price $209
Member Price $159