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Live Webinar

100-minute live streaming program
  • October 31
  • 1:00 - 2:40 pm EST

Form 8833 Treaty-Based Return Position Disclosure: Claiming a Treaty-Based Position

October 31

Gain a better understanding of the requirements for filing Form 8833 and what Treaty positions under Section 6114 entail.

The Tax Cuts and Jobs Act (TCJA) continues to have a profound impact on both domestic and international tax planning and compliance. With the passage of TCJA, it is more important than ever for taxpayers operating with and in countries with a tax treaty with the U.S., to identify and use treaty benefits, and to comply with the various treaty disclosure rules. This topic will help you identify whether a taxpayer has a requirement to file Form 8833. Understand what treaty positions under Section 6114 entail and decipher how dual-residence taxpayers under Section 7701 comply with treaty disclosure requirements. Gain knowledge on how to complete each line of Form 8833 and determine how to identify which section of the Internal Revenue Code is overridden by the applicable treaty. Obtain a working knowledge of how Form 8833 interacts with other filing obligations such as Form W-8BEN, Form 8802 and Form 1042 and understand the impact of TCJA on claiming treaty-based tax positions.

Learning Objectives

  • You will be able to explain the relationship between tax treaties and the Internal Revenue Code.
  • You will be able to discuss if you can obtain treaty benefits without completing Form 8833.
  • You will be able to review line by line instructions of Form 8833.
  • You will be able to describe the Tax Cuts and Jobs Act’s impact on treaty positions.

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Why Lorman?

Over 32 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

Relationship Between Tax Treaties and the Internal Revenue Code
  • Which Takes Precedence, a Treaty or a Code Provision
Form 8833
  • Can You Obtain Treaty Benefits Without Completing Form 8833
  • Who Must File Form 8833
  • What Is a Treaty Position Under Section 6114
  • Dual-Residents and Treaty Disclosures Under Regulation Section 301.7701(b)-7
Form 8833 – Line by Line Instructions
Form 8833 and Other Filing Obligations
The Tax Cuts and Jobs Act's Impact on Treaty Positions
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Why Lorman?

Over 32 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

Live Webinar Registration

  • AIPB 2.0
     
  • This program is acceptable for 2.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • Enrolled Agents 2.0
     
  • This program qualifies for 2.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     
  • CPE 2.0 including Taxes 2
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.0 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.0 hours. Prerequisite: basic knowledge of taxation. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     
  • Lorman Business Center, Inc. is a registered provider for CPA CPE through the State Education Department of New York, Sponsor number: 000640. The following course will carry the subject area of Taxation for 2.0 hours.
     

Who should attend?

This live webinar is designed for accountants, controllers, bookkeepers, CFOs, tax managers, and enrolled agents.

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Why Lorman?

Over 32 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

Thomas R. Alvarez, CPA, MBT

Thomas R. Alvarez, CPA, MBT

BGBC Partners, LLP

  • Senior tax manager with BGBC Partners, LLP and serves as the international and domestic adviser for the firm
  • Has worked with high-profile, high net-worth entertainment individuals, Fortune 500 manufacturing, retailing and distribution companies, ex-patriates, foreign trusts, estate issues with foreign considerations, and sophisticated business clients with extensive international tax issues requiring frequent travel to foreign countries to instruct and update subsidiaries and local tax personnel on United States tax laws
  • Before joining BGBC Partners, spent several years as a senior tax manager in the Los Angeles office of a Big 4 accounting firm, served as a tax director for an international conglomerate, a senior tax advisor for a multinational Fortune 100 company
  • Experience representing his clients before the IRS and state and local taxing authorities and has frequently spoken on tax panels for various industry groups, and often serves as a lecturer for various continuing professional educational courses for accountants and attorneys
  • Has been published in leading tax journals
  • M.A. degree in business taxation, University of Southern California; B.S. degree, California State University, Sacramento
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Why Lorman?

Over 32 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.

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Product ID: 405623
Published 2019
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