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Tax Implication of Cross Border Financing & Other Strategies

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Before starting this self study program, please go through the instructional document.


  • Common Inbound Investment Structures
    3 mins
  • Subsidiary vs. Branch Taxation
    9 mins
  • Shareholder Loans - ITA 15(2)
    22 mins
  • Back-to-back Loan - ITA 18(6)
    39 mins
  • Upstream Loans and Exempt Surplus
    48 mins
  • 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. 

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

Who Should Attend?

  • CPA - Mid Size Firm
  • CPA - Small Firm
  • CPA in Business
  • Young CPA