International Taxation 2024
2.00 Credits
Member Price $89
Non-Member Price $119
Overview
The tax consequences of a cross-border transaction can make or break any deal-and CPAs must know the basics and be aware of the traps. Get an introduction to the US taxation of cross-border transactions, focusing on taxation of foreigners investing in the US. Topics will cover: the basics of tax treaties, residency tests, effectively connected income, FDAP withholding, FIRPTA withholding, branch profits tax, ownership structures for non-resident aliens, gift and estate tax planning for foreign investors and pre-immigration income and estate tax planning. Limited discussion of taxation of outbound transactions, focusing on CFCs.
Highlights
- Income tax treaties
- Residence tests
- Effectively connected income
- FDAP and FIRPTA withholding
- Avoiding transfer taxation of foreign investors
- Pre-immigration tax planning
Prerequisites
Completion of an introductory course on international taxation or working knowledge of international tax rules.
Designed For
Accountants, business managers and CFOs.
Objectives
- Identify tax issues present in cross-border business transactions and investments
- Determine how to plan for and around international tax issues
Preparation
None
Leader(s):
Leader Bios
Jacob Stein, CalCPA Education Foundation
Jacob Stein, Esq., JD, LLM, is a partner with the law firm Klueger and Stein, LLP, in Los Angeles. The firm’s practice is limited to asset protection, domestic and international income and estate tax planning and structuring complex business transactions. Mr. Stein received his law degree from the University of Southern California, and his Master’s of Law in Taxation from Georgetown University. He has been accredited by the State Bar of California as a Certified Tax Law Specialist and is AV-rated (highest possible rating) by Martindale-Hubbell. Mr. Stein is an author of numerous tax and asset protection articles and technical manuals and a frequent lecturer to various attorney, CPA and other professional groups. He is an adjunct professor of taxation at the CSU, Northridge Graduate Tax Program.
Non-Member Price $119
Member Price $89