International Taxation: Inbound Transactions

Overview

An examples-based discussion of key concepts, including effectively connected income, branch profits tax (BPT), branch-level interest tax, Form 1120-F, and more.

Highlights

Key Topics

• Effectively connected income
• Branch profits tax
• Income sourcing
• Withholding requirements
• Foreign Account Tax Compliance Act (FATCA)
• Foreign Investment in U.S. Real Property Tax Act of 1980 (FIRPTA)
• U.S. real property interest (USPRI)

Prerequisites

Basic knowledge of U.S. federal income taxation

Designed For

Who Will Benefit

Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Objectives

Learning Outcomes

• Identify the tax consequences of having U.S. effectively connected income (ECI).
• Determine whether an activity constitutes U.S. trade or business.
• Determine the branch profits tax (BPT) and branch-level interest.
• Identify the basics of tax withholding for nonresident aliens and taxation under the Foreign Account Tax Compliance Act of 2010 (FATCA).
• Identify how to determine the character and source of income for different payment types.
• Identify a withholding agent and the rules that apply to withholding agents.
• Determine when the Foreign Investment in Real Property Tax Act (FIRPTA) applies and does not apply.
• Identify FIRPTA exclusions and exceptions with respect to U.S. real property interests (USRPIs).