4194 | On Demand | Basic | Self-Study
U.S. International Tax: Advanced Issues
Friday, May 1, 2020 - Friday, April 30, 2021
This comprehensive learning program helps global finance and accounting professionals navigate the highly complex world of international taxation.
Developed in partnership with Grant Thornton, this certificate program is valuable to anyone who needs to understand the complexities of international taxation.
The U.S. International Tax: Advanced Issues bundle dives deeper into how to handle complex tax issues such as transfer pricing, tax treaties and corporate formations.
Objectives
Identify the accepted transfer pricing methods and when it's appropriate to use them Recall how U.S. tax treaties determine U.S. tax residency and how it impacts eligibility under the treaty Distinguish how hybrid entities are treated under U.S. income tax treaties Assess whether a U.S. person's transfer of property to a foreign corporation should generally qualify for non-recognition treatment under section 351 Assess whether a reorganization or restructuring may qualify as an "inversion" subject to the rules of section 7874
Designed For
Public and corporate tax professionals.
Highlights
Section 351 Transfer Pricing Permanent establishment Tax Treaties BEPS overview Reorganizations Stock acquisitions Corporate formation Inversions