International Tax Treaties
2.00 Credits
Member Price $109
Non-Member Price $139
Overview
This course presents an overview of tax treaties and how they are used in structuring transactions and determining the tax impact of cross-border transactions. It discusses the ordering rules for local laws versus treaty laws, and the purpose of the tax treaties in avoiding and eliminating double taxation to promote trade and investment. The participant will learn about planning opportunities to contemplate when structuring foreign operations.
**Please Note: If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to kori.herrera@acpen.com.
Highlights
- Tax treaties
- Tax impact of cross-border transactions
Prerequisites
None
Designed For
This course is suitable for Corporate tax and finance executives, directors, managers and staff, CPAs, CAs Enrolled Agents, accountants, attorneys and business/financial advisors who work with and advise businesses that have cross-border operations and issues. All in-house and public practice professionals involved with international tax compliance and planning will benefit from this timely and insightful seminar.
Objectives
- Be able to discuss common treaty provisions in the US Model Treaty.
- Understand typical reduced withholding rates on dividends, interest and royalties.
- Describe the purpose of income tax treaties in the tax regimes of countries.
- Acquire a better understanding of the international tax environment.
- Recognize qualifications for a permanent establishment
- Describe the rules by which a taxpayer must disclose a tax position to the IRS for claimed treaty benefits that is in conflict with the IRC.
- Ascertain mutual agreement procedures between the taxing authorities of two treaty countries in cases of double taxation.
- Recognize when a company/citizen would need to file Form W8-BEN with the IRS in order to claim treaty benefits for US tax withholding.
Preparation
None
Leader(s):
Leader Bios
Allison McLeod, University of North Texas
Allison M. (Yee) McLeod, LL.M., JD, CPA, is currently a Senior Lecturer at the University of North Texas in Denton, Texas. She received Bachelor of Business Administration and Juris Doctor degrees from Baylor University, and a Master of Legal Letters (LL.M.) degree specializing in Taxation from the Southern Methodist University School of Law. Professor McLeod has also studied British and Art History at the University of Sussex, England. Prior to joining the UNT faculty in 2010, Professor McLeod held the position of Director of Tax Planning and IRS Audits for Lehigh Hanson North America, a major manufacturer of cement, aggregates and other building materials. Her practice included both federal and international tax planning. Professor McLeod also spent thirteen years specializing in Tax Planning with the JCPenney Corporation, Inc., and two years with Deloitte & Touche in Dallas. Professor McLeod has taught at the university level graduate classes on Ethics, Tax Research, Multi-jurisdictional Taxation and Corporate Income Tax. She also lectures in Financial Accounting and Individual Taxation on an undergraduate level. She has taught at the UNT College of Law as adjunct faculty and works part-time at the law firm of Grable Martin Fulton, PLLC. Since 2011, Professor McLeod has been honored to present live and on-line ethics CPE classes to CPAs across the nation. She also serves as an expert witness in accounting malpractice cases and maintains a small private practice serving individuals and small businesses. Professor McLeod has also taught at the University of North Texas College of Law as adjunct faculty. She is currently serving on the Professional Ethics Committee of the Texas Society of CPAs. Professor McLeod is licensed to practice law by the State Bar of Texas since 1992 and has been a Certified Public Accountant since 1993.
Non-Member Price $139
Member Price $109