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Income Tax Treaties - Advanced Planning

Understand treaty planning techniques, what must be done to obtain treaty benefits and how to avoid common pitfalls.

Better understand the ins and outs of U.S. income tax treaty planning and learn creative techniques to navigate some of the more complex cross border transactions. Through the use of real world examples, we will walk through planning ideas and identify some of the challenges and pitfalls common in treaty planning. You will also learn about the proposed changes to the U.S. model treaty, the global context in which these changes are being made, and the practical impact the changes could have on planning.

Runtime: 96 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

Overview of U.S. Tax Treaties

  • Fundamentals of U.S. Income Tax Treaties
  • U.S. Treaty Network
  • Treaties Awaiting Ratification

Planning Techniques

  • Satisfying the Limitation on Benefits
  • Use of Hybrid Instruments
  • Holding Company Structures
  • Conduit Financing Arrangements
  • Considerations and Pitfalls in Treaty Planning

Proposed Changes to the U.S. Model Tax Convention

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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 Webinar

This course was last revised on March 24, 2016.

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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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

Scott A. Harty

Scott A. Harty

Alston & Bird LLP

  • Partner at Alston & Bird LLP in Atlanta
  • Focuses practice on complex domestic and cross-border commercial transactions, including taxable and tax-free mergers and acquisitions, joint ventures and corporate restructurings
  • Has substantial experience advising corporate and private clients on all facets of U.S. inbound and outbound investments, including treaty planning, investments in U.S. real estate, Subpart F and withholding tax issues arising under FATCA
  • Represents clients in tax controversy matters through the audit process and administrative appeals, including the negotiation and settlement of taxes and civil penalties
  • Handled tax audits for public and private companies, income and gift tax audits for individuals and cases with significant offshore trust and foreign corporate tax issues
  • Frequent speaker and has been recognized by Chambers USA as one of the leading tax lawyers in Georgia
  • Advised the federal government of Canada on cross-border tax issues in connection with its US $9.5 billion loan to General Motors
  • Advised on U.S. and cross border tax issues in connection with a US $3.0 billion debt offering by a publicly traded company
  • Represented a U.S. owned foreign group in a $100 million restructuring of its overseas operations
  • Advised on a $300 million tax-free split off of a privately held company in connection with a shareholder dispute
  • Represented a publicly traded company in protest of a $45 million IRS adjustment in connection with transactions among the affiliated group
  • Advised a U.S.-based client on the corporate structuring and tax implications of operations in East Africa, including tax issues related to the development and exploitation of intellectual property, withholding taxes and financing operations
  • J.D. degree, Vanderbilt University; LL.M. degree, in tax, New York University
Jeffrey L. Rubinger

Jeffrey L. Rubinger

Bilzin Sumberg

  • Partner at Bilzin Sumberg in Miami
  • Practices in the area of domestic and international taxation
  • Has been involved in tax planning for cross border mergers and acquisitions, international restructurings and joint ventures, and in the use of financial products in cross-border settings
  • Experienced in a broad range of transactions involving U.S. taxpayers doing business overseas, foreign taxpayers conducting business in the United States, as well as federal, state and local tax issues involving corporate reorganizations, partnerships, and subchapter S corporations
  • Lectures and has published several articles on domestic and international tax topics, including the taxation of financial products, the Foreign Investment in Real Property Tax Act, international tax consequences of cancellation of indebtedness income, the taxation of qualified subchapter S subsidiaries, Check-the-Box tax planning, subpart F income minimization, foreign tax credit planning, and tax planning with foreign holding companies
  • Prior to attending law school, he practiced as a certified public accountant at a major accounting firm and holds an inactive certified public accountant license from the State of Florida
  • Adjunct tax professor at the University of Miami School of Law, LL.M. in Taxation Program where he has taught classes on advanced international taxation and the taxation of financial products
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Product ID: 397254
Published 2016
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