Overview
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Common Inbound Investment Structures
3 mins
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Subsidiary vs. Branch Taxation
9 mins
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Shareholder Loans - ITA 15(2)
22 mins
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Back-to-back Loan - ITA 18(6)
39 mins
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Upstream Loans and Exempt Surplus
48 mins
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Repatriation Strategies
56 mins
Course Description
Cross-border financing refers to the process of providing funding for business activities that occur outside a country's borders.
Cross border financing within corporations can become very complex, mostly because almost every inter-company loan that crosses national borders has tax consequences. This occurs even when the loans or credit are extended by a third party, such as a bank.Â
The online continuing professional development course offers an overview for the most tax-efficient ways of financing overseas operations.
This online CPE/CPD webinar covers the following key topics-
Common inbound investment structures
- Taxation of Branch vs. Subsidiary
- Walkthrough of a Branch Tax Return and Schedule 2
Cross Border Financing
- Shareholder loans - 15(2)
- Pertinent loan or indebtedness (PLOI)
- Imputed interest on Interest free or low interest loans - 17(1)
- Thin-capitalization
- Back-to-Back Loan Rules
- Upstream Loan
- Foreign Affiliate Dumping
Strategies to repatriate profits
- Transfer Pricing Strategies
- Dividend and Withholding taxes
- Inter-company charges for the management fee, royalties, and similar payments
- Return of Capital
- Repayment of Existing debt
- New loans and issues to consider
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Learning Objectives
- To discuss common structures for tax purposes
- To discuss major differences between subsidiary and branch taxation
- To discuss in detail about upstream loans and FAD
- To discuss foreign affiliate dumping
- To discuss various repatriation strategies
Recommended For
- This online Taxes CPD/CPE course is recommended for CPAs, CMAs & All Accounts & Finance Professionals involved in the role of CFO, Controller, Finance Director, and Tax Director.
Who Should Attend?
- CPA - Mid Size Firm
- CPA - Small Firm
- CPA in Business
- Young CPA