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

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.

Runtime: 98 minutes
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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.

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OnDemand Webinar

This course was last revised on October 31, 2019.

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

  • 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).
     

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

Audio & Reference Manual

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

MP3 Download

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

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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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Product ID: 405623
Published 2019
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