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U.S. Tax Treaties: What You Need To Know

 

Gain a basic understanding on United States tax treaties and how they are enacted.

Income tax treaties play an integral role in international business transactions, impacting taxpayers whose activities cross borders into the jurisdiction of one of the U.S.'s many treaty partners. In the uncertain international business environment we currently find ourselves in, it's more important than ever for companies to understand the benefits of income tax treaties and how they affect and benefit cross-border planning. This topic will provide you a background of the fundamental aspects of income tax treaties: including why treaties are so important, how they are enacted, and how they impact existing domestic legislation. The major treaty provisions of the U.S. Model Treaty will be reviewed so that you will understand how treaties apply to various business activities and cross-border transactions.

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U.S. Tax Treaties: What You Need To Know

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U.S. Tax Treaties: What You Need To Know

Faculty

Matt Anzalone

Matt Anzalone

Crowe LLP

  • Serves as a senior staff with Crowe LLP’s international tax group
  • More than 6 years of experience in international tax including both compliance and planning for public and private companies
  • Has a broad range of industry experience, including manufacturing and distribution, retail and technology, among others
  • Throughout his career he has acquired extensive experience in international compliance issues including completion and review of all U.S. international tax forms
  • Since 2013, he has focused on providing international tax services to publicly and privately held multinational companies on a wide range of international tax issues, including, in addition to the above, structure planning, mergers and acquisition, cross-border transactions, Subpart F and GILTI analysis
  • Prior to joining Crowe, he spent 5 years working at both private and public multinational companies where he gained an extensive background optimizing their tax positions and internal compliance processes as well as their annual transfer pricing reporting and documentation
  • Has specific experience in analyzing tax compliance reporting requirements and developing international cash repatriation projects
  • M.S. degree in taxation, Northern Illinois University
Mario A. de Castro

Mario A. de Castro

Crowe LLP

  • Managing director with Crowe LLP’s Washington, D.C. office
  • For more than 15 years, he has been counseling both private and public companies in the areas of corporate and international tax and related international corporate and business matters
  • Experience includes advising clients with ongoing international operations and expanding overseas; his experience has included advising on merger and acquisition due diligence; supply chain and intellectual property planning, ongoing structure analysis; and intercompany transaction maintenance for companies operating throughout the world
  • He has written articles and presented numerous times at seminars in the U.S., Europe, and Latin America on international tax matters, and related industry-specific topics ranging from mergers and acquisitions, supply chain planning, life sciences industry-specific tax issues, U.S. tax reform, cryptocurrency, and the digital economy and e-commerce
  • He is licensed to practice law in the State of Florida
  • Member of the Florida Bar Associaiton (Tax Section), International Fiscal Assosciation (D.C. Branch), American Bar Assosiation (Tax Section)
  • LL.M. degree in taxation, international tax certificate, University of Miami School of Law; J.D. degree, Temple University School of Law; B.A. degree in international relations and Latin America studies and economics, Tulane University
  • Can be contacted at 202-552-8021, [email protected] or at https://www.linkedin.com/in/mariodecastro
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U.S. Tax Treaties: What You Need To Know

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