Tax advisers often overlook the classification of foreign business interests owned by U.S. individuals for U.S. tax purposes. U.S. tax counsel must recognize that the IRC, not the situs country's laws, determines how to classify a U.S. taxpayer's foreign business holding. Foreign entities are subjected to United States income tax requirements when their income is effectively connected to the United States. Such entities can create tax and reporting requirements for U.S.-based stakeholders as well.
Critically, the United States maintains its own distinct rules for classification of foreign entities and those rules are in no way impacted by how the entity is taxed in its home jurisdiction! In identifying the proper tax classification of a foreign business holding, advisers first must determine whether the business organization qualifies as a taxable entity separate from its owner(s), and if so, whether the entity is appropriately considered a trust or a business organization under U.S. tax law.
Join this webinar for an in-depth discussion of the relevant considerations in this context, including tax ramifications for foreign trusts, foreign corporations, and foreign pass-through entities. Listen as our expert panelist provides a thorough and practical guide to the tax and operational impacts of entity classification of foreign interests owned by U.S. taxpayers.
Learning Objectives
To be aware about on how foreign organizations are classified for U.S. tax purposes.
To learn about the special rules applicable to U.S. shareholder of foreign corporations.
To gain relevant knowledge on how to choose an entity type.
To identify when a foreign entity becomes subject to U.S. tax or informational reporting requirements
To learn about available elections and planning, to ensure favorable U.S. tax classification of foreign business entities
MY-CPE LLC (Sponsor Id#: 143597) 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 website: www.NASBARegistry.org.
MY-CPE LLC (Sponsor Id#: GEHNZ) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary
MY-CPE LLC (Sponsor ID# : 6273) has been approved by the California Tax Education Council to offer continuing education courses that count as credit towards the annual “continuing education” requirement imposed by the State of California for CTEC Registered Tax Preparers. A listing of additional requirements to register as a tax preparer may be obtained by contacting CTEC at P.O. Box 2890, Sacramento, CA, 95812-2890, toll-free by phone at (877) 850-2832, or on the Internet at www.ctec.org.
Patrick is a partner with Culhane Meadows, a national law firm with a prominent practice in the international area. Patrick practices exclusively in the area of international taxation. He has extensive experience in handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with international tax issues faced by their clients. Patrick is a prolific contributor to a multitude of international tax journals, including Tax Notes and the Journal Of International Taxation, . He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPA Academy on assorted international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and a LL.M. from New York University School of Law. His bar admissions include Pennsylvania, Florida, New Jersey and Georgia. Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication, named Patrick Estate Planning Lawyer of the Year (United States) for both 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.
Culhane Meadows is proudly shaking up the legal marketplace by offering exceptional, yet highly-efficient and cost-effective, client services provided exclusively by partner-level attorneys with substantial experience from large law firms or in-house legal departments of respected corporations.
FAQ
To receive Continuing Education credit for the event, you must register for the webcast prior to the start of each program.
Continuing Education Credit Certificate is available to all eligible participants within 24 hours of each webinar.
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Our courses meet the global Continuing Professional Development (CPD-IES7) Standard for Chartered Accountants with International Education Standard 7 (IES 7) set by The International Federation of Accountants (IFAC), the International Accounting Education Standards Board (IAESB) and the Association of Chartered Certified Accountants (ACCA). Based on our accreditation by existing IFAC members and affiliates, we believe learners can count their professionally relevant, verifiable learning activities on myCPE, including taking on demand courses and attending live webinars, toward fulfillment of their verifiable CPD-IES7 requirements. However, if there is any question, we recommend that the individual learner confirm with his/her professional licensing organization before taking myCPE courses for CPD-IES7 credit.
You can manage your continuing education certificates and credits through your certificate dashboard which is available when you are logged in to your account (LOGIN)
As an accredited provider of Continuing Professional Education in the United States, myCPE online learning platform, courses, and webinars meet the requirements set forth by the Institute of Management Accountants (IMA), an IFAC Member Organization, as well as the National State Boards of Accountancy (NASBA) and the Institute of Internal Auditors (IIA), both IFAC Affiliates. As well as it has been approved by NASBA, Internal Revenue Service (IRS), Certified Financial Planner Board (CFP Board), California Tax Education Council (CTEC), Society of Human Resource Professional (SHRM), Human Resource Certification Institute (HRCI) and many more.Therefore, we believe learners can count their professionally relevant, verifiable learning activities on myCPE, including taking on demand courses and attending live webinars, toward fulfillment of their verifiable continuing education requirement as CPD-IES7 requirements. However, if there is any question, we recommend that the individual learner confirm with his/her professional licensing organization before taking myCPE courses for CPD-IES7 credit.
myCPE Courses are taken by : CPA | CMA | CFE | CIA | CPA(Yellow Book)| CFP | CFA | CPA (Govt.) | EA | CRTP | MRTP | ORTP | ABV | CITP | CVA | PFS | CFF and others.
Refund/Cancellation Policy
For more information regarding refund, complaint and program cancellation policies, please contact our offices at 646-688-5128
In case any of the course or live webinars gets cancelled we would be refunding you the entire amount (if paid).
Testimonial
4.3
(41)
41%
49%
10%
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WY
Wenyi Yin ,
Jan 25th 2021
Excellent instructor and board knowledge
LD
Lacy Dennis ,
Jan 26th, 2021
I really enjoyed the webinar. I am more familiar with personal foreign holdings rather than the business side so I appreciated the chance to grow my knowledge.
