COURSE OBJECTIVES: This course covers the principles of US taxation of business activity, with a specific focus on inbound taxation. The course moves through consideration of the causes of US tax, and the computation of US taxable income to the US approach to tax treaties. The separately bookable day-one in this series concentrates on outbound taxation.
COURSE CONTENT
General US Tax Concepts
- Classification and Taxation of Entities
- Check-the-Box
- Source of Income
US Taxation of Foreign Corporations
- FDAP Income
- Effectively Connected Income of a US Trade or Business
- Walkthrough of Form 1120-F
Tax Treaty Planning
- Concept of Residence
- Permanent Establishment and Business Profits Threshold
- Dividends, Interest, Royalties and Rents
- Other Types of Income
- Anti-Treaty Shopping – Limitation on Benefits
Acquisition of US Operations
- Taxable Acquisitions
- Tax-Free Acquisitions
Financing the US Operation
- Payments and Deductibility
- Earnings Stripping
- Branch Financing Transactions
- Multinational Financing Techniques
- Withholding Taxes
Liquidations
- Taxable Liquidations
- Tax-Free Liquidations
- Liquidations in the Inbound Context
Miscellaneous Topics
- US Taxation of Intangible Property
- Foreign Investment in US Real Estate
WHO SHOULD ATTEND
Those needing a basic background in the US corporate tax system. The course requires delegates to have an understanding of the principles of international taxation.
Would you like this course run in-house? Call us on 0207 566 8207 to find out more
Not quite what you were looking for?
Then please see the following closely related course:
Corporate Taxation in the USA - Outbound Taxation