Introduction to US international corporate taxation: London, dates to be confirmed
Nov 27-29
A comprehensive overview of US international tax focusing on inbound and outbound investment by corporations
This course is ideal for those new to US international tax or who work in the area less frequently. Many participants at previous courses work in the tax departments of US companies outside the US and wish to broaden their understanding of the principles and/or the work done by their colleagues in the United States. It is also ideal preparation for those planning to take the Advanced Diploma in International Taxation exam US option but who have little existing knowledge and need an introduction to a very different tax system before tackling the more complex areas that our in-depth course addresses. (The tutor will assume that participants are familiar with international tax concepts generally.) The compact nature of the course, just three days, makes it ideal for busy professionals and/or those travelling from outside the UK.
Please note that the course focuses on corporate tax issues.
Call +44 (0)1962 458058 or email deborah@djhinternationaltax.com for more details.
What is covered
- The structure of the US tax system
- US federal income taxation: overview
- Inbound investment
- Outbound investment
- Other issues: transfer pricing, anti-avoidance, indirect taxes
The structure of the US tax system
- Federal taxation vs. state and local taxation
- The federal tax system: the Internal Revenue Code
US federal income taxation: overview
- Basic rule: taxation of worldwide income of US “persons”
- Individuals
- Corporations
- Partnerships
- Trusts and estates
- Classification of business entities: the “check the box” regime
- Basic rules regarding taxation of non-US persons
- Source of income: section 861 et seq.
Inbound investment
- Non-US persons engaged in the conduct of a US trade or business
- Non-US persons not engaged in the conduct of a US trade or business
- Foreign Investment in Real Property Tax Act
- Special US tax treaty issues: Limitation of benefit articles, saving clauses, treaty overrides
- Specific anti-avoidance rules: interest-stripping and anti-conduit regulations
Outbound investment
- Foreign tax credit
- Anti-deferral rules
- Outbound transfers: Code section 367
Other issues
- Transfer pricing rules: Code section 482 and regulations
- Anti-avoidance: general case law doctrines and main statutory provisions
- Indirect Taxes: customs duties; state and local sales taxes
Pricing for 3-day course: £1600 plus VAT at 20%
Cost includes full course documentation and access to a trial of a specially selected section of materials online. Participants are encouraged to sign up for the materials shortly before the course and review the content before attending. The price of the course itself includes lunch and refreshments throughout.
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