Overview
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Hypothetical fact pattern
5 mins
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Income tax treaties - Basic structure
10 mins
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Income tax treaties - Who can obtain benefits?
28 mins
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Tax treaties - Common provisions
52 mins
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FDAP income modification examples
83 mins
Course Description
Income tax treaties primarily function to permit qualified tax residents of a treaty party country to (beneficially) modify statutory rules of source-country taxation. For nonresidents, a prerequisite to tax analysis is ascertaining whether the nonresident can utilize an American tax treaty – as their scope/rates of tax are substantially modified if so.
The United States maintains income tax treaties with roughly seventy countries, with each treaty containing distinct terms/articles built around common principles. Under treaties, residents of a treaty country can be taxed at a reduced rate, or even exempted from tax, on specified items of income from the other country. The savings clause prevents a United States citizen/resident/entity from using a tax treaty to alter tax on US source income.
Speaker Patrick McCormick in this CPE course covers threshold-level considerations for nonresident tax standards under income tax treaties.
Following are the major topic covered in this online IRS Approved taxation course:
- Income Tax Treaties - Basic Structure
- Income Tax Treaties - Who Can Obtain Benefits?
- Tax Treaties - Common Provisions
- Permanent Establishments
- Permanent Establishment Mechanics
- Permanent Establishments in a Digital Economy
- Tax Treaties - FDAP Income
- FDAP Income Modification Examples
- Reporting Requirements
In this CE/CPE webinar, a brief review of statutory rules is provided for context, with an overview of the function of tax treaties then provided. Focus is then given to qualification for treaty benefits. Specific treaty standards are then evaluated in detail.
Learning Objectives
- To discuss threshold-level considerations for nonresident tax standards under income tax treaties.
- To review statutory rules
- To analyze the function of tax treaties.
- To discuss qualifications for treaty benefits.
- To evaluate specific treaty standards in detail.
Recommended For
- This IRS-approved CE webinar is recommended for CPAs, EA, AFSP, CRTP, MRTP, ORTP, CFIRS, CWS, tax partners, tax return preparers, tax attorneys, and other tax practitioners who want to understand threshold-level considerations for nonresident tax standards under income tax treaties.
- This CPE/CE course is also helpful for tax professionals who want to understand everything about Pre-Immigration tax planning.
Who Should Attend?
- Accountant
- Accounting Firm
- Accounting Managers
- CPA (Industry)
- CPA - Mid Size Firm
- CPA - Small Firm
- Maryland Tax Preparers
- Oregon Tax Preparers
- Senior Accountant
- Staff of Accounting Firm
- Tax Accountant (Industry)
- Tax Attorney
- Tax Director (Industry)
- Tax Firm
- Tax Managers
- Tax Practitioners
- Tax Preparer
- Tax Professionals
- Tax Pros
- Young CPA
