In-depth US international corporate taxation: March 2019
Mar 26-29
Goes deeper into the detail of US corporate tax as it applies to international transactions
This course is ideal for those who have been working with US international tax for some time and now wish to explore some of the more complex areas. And because its structure mirrors the syllabus for paper 2 of the Advanced Diploma in International Taxation it is ideal preparation for those planning to take that exam. The level of knowledge required will assume that you have either attended the “Introduction to US international taxation” course or already are comfortable to that level. The compact nature of the course, just 4 days, makes it ideal for busy professionals and/or those travelling from outside the UK.
Most participants at the 2017 course were planning on taking the exam in June of the same year, several already having attended the introductory course in November 2016. Here’s what one had to say: “Very good course. Not only did it give us the need information but also the confidence to tackle the exam. Narelle is an excellent tutor.”
One statistic of which we are rather proud is that in 2017, for the third year, one one of our course participants received the medal for the highest mark in an ADIT paper 2 exam, this year Naomi Wells with a staggering 96%! While all credit must go to the students they have each been kind enough to say that they feel they were more successful thanks to the training course and Narelle MacKenzie’s teaching.
All courses take place at a dedicated training venue in central London. Call +44 (0)1962 458058 or email deborah@djhinternationaltax.com for more details.
What is covered
- Basic rules and concepts
- Inbound
- US tax treaties
- Information Reporting
- Outbound
- Transfer pricing
- Cross-border M&A
- Other issues: Foreign trusts; Federal estate tax; Federal gift tax; State and local taxes
- Past Papers 2
Basic rules and concepts
- US taxpayers: individuals, corporations and others
- Entity classification
- Residency test for individuals
- Source of income and capital gains
- Withholding tax principles
- Bilateral tax treaties
- Corporate groups and consolidated returns
- General anti-avoidance: substance over form
Inbound
- US trade or business of a foreign person
- Effectively connected income
- Branch profits tax
- Related party financing of US subsidiary
- Debt vs equity
- Earnings stripping rules
- Distributions form US subsidiary
- US source payment where no US trade or business
- Safe harbours for US investment activity
- Anti-conduit rules
- Foreign Investment in US real property interests
US tax treaties
- The OECD model and the US model
- Limitation on benefits provision
- Provisions relating to hybrid entities
Information reporting
- Foreign Account Tax Compliance Act (“FATCA”)
- Foreign bank reporting and entity information returns
- Exchange of Information and cooperation between revenue authorities
Outbound
- Foreign tax credit: direct and indirect
- Corporate transfers to foreign subsidiaries
- Distributions from foreign subsidiaries
- Foreign currency rules
- Controlled foreign corporations
- Passive Foreign Investment companies
- Investment in foreign partnerships, funds
Transfer pricing
- The US approach to transfer pricing
- Cost sharing for research and development
- Global trading of securities
- Transfer pricing of intangibles
Cross-border M&A
- Tax-free reorganizations
- Outbound reorganizations
- Inbound reorganizations
- Carryover of tax attributes, losses
Other issues
- Foreign trusts
- Federal estate tax
- Federal gift tax
- State and local taxes
Past Papers 2
Pricing for 4-day course: £1800 plus VAT at 20%
Cost includes full course documentation and refreshments including lunch throughout
Nov 15
US expatriate tax year-end conference: 15 November 2018
Be up to date with developments as we approach the calendar and US tax year end
From £375 plus VAT
Jan 01
International corporate taxation: Four one-day masterclasses in London, Dates to be confirmed
A detailed and comprehensive consideration of the application of tax law to international transactions in four self-contained days
£1950 + VAT if all four days are booked
