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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.

Runtime: 102 minutes
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

General Purpose of Treaties

Legal Basis of Treaties

  1. S. Treaty-Making Process
  2. Interpretation of U.S. Treaties

    Discussion of Treaty Provisions

    • Eligibility for Treaty Benefits
    • Residency Rules
    • Permanent Establishment
    • Business Profits
    • Dividends, Interest and Royalties
    • Limitation on Benefits
    • Administrative Provisions
    • Other Provisions

    Treaty-Based Return Positions

    1. S. Treaty Network
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

This course was last revised on July 29, 2020.

Call 1-866-352-9540 for further credit information.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • ME CLE 1.5
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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

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Product ID: 406221
Published 2020
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