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Tax Implication of Cross Border Financing & Other Strategies

  • Accountant
  • CPA (CA)
  • CMA
  • CPA (US)
  • CFIRS
  • CWS

Published: July, 2021

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

  • Course Description
  • Course Qualification
  • Presenter
  • FAQ

Course Description

Overview

  • 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

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

Course Qualification

Webinar Qualifies For

  • 1 CPE Credit of Taxes for Certified Public Accountants (CPA-US)
  • 1 CPE Credit for Certified Management Accountants (CMA)
  • 1 CPD Credit for Chartered Professional Accountant (CPA Canada)
  • 1 CE Credit for Certified Fiduciary & Investment Risk Specialist (CFIRS)
  • 1 CE Credit for Certified Wealth Strategist (CWS)
  • 1 General Credit for Accountant/Bookeeper

Additional details

  • Course Level :
    Basic
  • Credits :
    1
  • Instructional Method :
    QAS Self Study
  • Pre-requisites :
    None
  • Advance Preparation :
    None

NASBA APPROVED

MY-CPE LLC, 1600 Highway 6 south, suite 250, sugar land, TX, 77478

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.

Presenter

About Presenter

Big4 CPA

Founder, AK Consulting Inc.

We are a team of Big4 CPA, CA and other professionals. We offer wide range of professional development courses for CPA members relating to Canadian Taxation, International tax, Accounting, Ethics, Business, Workplace Teams & Culture, High Performance, Soft skills, and Personal Development.

We also work with third party content creators to offer unique CPD for our CPA members, such as on latest technology, cyber security, digital marketing. and various other interesting topics.


Faq

FAQs content

  • 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.
  • You must attend complete live webinar and respond to all polling questions asked during the webinar. Credits would be issued on 50 minute credit hour basis.
  • Polling feature Not supported: If you are logging in through browser or web portal in the browser (zoom.us) it doesn’t support the polling feature. Please be advised the current polling feature can only be supported via Zoom desktop and mobile app. You can check the same here : https://support.zoom.us/hc/en-us/articles/203749865-Polling-for-webinars
  • This event may be a recorded rebroadcast of a live event done in past and the instructor will be available to answer your questions during/after the webinar.
  • If you still face the polling problem please don’t panic and provide your response in the chat and we shall consider the same for processing for credits. You can download Zoom by clicking on the mentioned link : https://zoom.us/download
  • 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.

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