Fundamentals of Inbound US Rules of International Taxation 2024

Overview

The United States loves to tax the US source income of foreign individuals and businesses. This program will cover the U.S. taxation of their passive and business income (and how tax treaties impact that taxation) before diving into the transfer pricing rules.

Highlights

• Withholding on dividends, interest, rents, royalties, and compensation • Withholding rules on foreign investment in US Real Estate • 163(j) and Base Erosion Anti-abuse Tax restrictions on repatriation • Foreign Persons with a US Trade or Business • Taking advantage of tax treaties • Tax-Advantaged Transfer Pricing • IRS Audit Tools for Foreign-Owned Corporations

Prerequisites

None

Designed For

CPAs and tax professionals that work with international tax issues.

Objectives

• Identify issues with respect to cross-border transactions • Determine when the income is subject to the US tax net • Recognize opportunities for tax minimization strategies

Preparation

None