Description:  This course presents an overview of tax
treaties and how they are used in structuring transactions and determining the
tax impact of cross-border transactions. 
It discusses the ordering rules for local laws versus treaty laws, and
the purpose of the tax treaties in avoiding and eliminating double taxation to
promote trade and investment. The participant will learn about  planning opportunities to contemplate when
structuring foreign operations.

Who
should attend:  This
course is suitable for Corporate tax and finance executives, directors,
managers and staff, CPAs, CAs, Enrolled Agents, accountants, attorneys and business/financial
advisors who work with and advise businesses that have cross-border operations
and issues.  All in-house and public
practice professionals involved with international tax compliance and planning
will benefit from this timely and insightful Course.

Program Content:

·        
Territorial vs. Extraterritorial taxation.

·        
Purpose of treaties

·        
Permanent establishment

·        
Interpreting treaties

Learning objectives:  By the end of the course, the participant should be able to:

1.      Be
able to discuss common treaty provisions in the US Model Treaty.

2.      Understand
typical reduced withholding rates on dividends, interest and royalties.

3.      Describe
the purpose of income tax treaties in the tax regimes of countries.

4.      Acquire
a better understanding of the international tax environment.

5.      Recognize
qualifications for a permanent establishment

6.      Describe
the rules by which a taxpayer must disclose a tax position to the IRS for
claimed treaty benefits that is in conflict with the IRC.

7.      Ascertain
mutual agreement procedures between the taxing authorities of two treaty
countries in cases of double taxation.

8.      Recognize
when a company/citizen would need to file Form W8-BEN with the IRS in order to
claim treaty benefits for US tax withholding.