A comprehensive overview of US international tax focusing on inbound and outbound investment by corporations

This course is ideal for those new to US international tax or who work in the area less frequently. It is ideal preparation for those planning to take the Advanced Diploma in International Taxation exam US option but who have little existing knowledge and need an introduction to a very different tax system before tackling the more complex areas that our in-depth course addresses. (The tutor will assume that participants are familiar with international tax concepts generally.) The compact nature of the course, just three days, makes it ideal for busy professionals and/or those travelling from outside the UK. Since there is no longer a paper in the Advanced Diploma in International Taxation directly associated with this course (it was formerly preparation for US paper III) we have reduced the length – and price – of the course to remove the exam question practice. Those who wish to review some exam questions however, may attend a late afternoon/early evening session on the second day.

Please note that the course focuses on corporate tax issues.

Call +44 (0)1962 458058 or email deborah@djhinternationaltax.com for more details.

Course tutor:
Narelle MacKenzie is a well-known international tax consultant with over 25 years of experience working in international taxes, in both professional practice, industry and teaching. She primarily works with tax advisors, CPAs, attorneys, and in-house tax departments to identify optimal, strategic tax solutions.

Pricing for 3-day course: £1550 plus VAT at 20%
Cost includes tuition, including many worked examples, full course documentation and access to a trial of a specially selected section of materials online. Participants are encouraged to sign up for the materials shortly before the course and review the content before attending. The price of the course itself includes lunch and refreshments throughout.
 
“I saved the course fee several times over using something I learned from Narelle in the first hour of this course” JS, UK
 
Topics covered:
The structure of the US tax system
Federal taxation vs. state and local taxation
The federal tax system: the Internal Revenue Code
US federal income taxation: overview
Basic rule: taxation of worldwide income of US “persons”
Inbound investment
Non-US persons engaged in the conduct of a US trade or business
Non-US persons not engaged in the conduct of a US trade or business
Foreign Investment in Real Property Tax Act
Special US tax treaty issues: Limitation of benefit articles, saving clauses, treaty overrides
Specific anti-avoidance rules: interest-stripping and anti-conduit regulations
Outbound investment
Foreign tax credit
Anti-deferral rules
Outbound transfers: Code section 367
Other issues
Transfer pricing rules: Code section 482 and regulations
Anti-avoidance: general case law doctrines and main statutory provisions
Indirect Taxes: customs duties; state and local sales taxes

Pricing for 3-day course: £1550 plus VAT at 20%
Cost includes full course documentation and access to a trial of a specially selected section of materials online. Participants are encouraged to sign up for the materials shortly before the course and review the content before attending. The price of the course itself includes lunch and refreshments throughout.

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