Bloomberg BNA: Basics of International Tax Planning

 

Bloomberg BNA recently requested that I present on the basics of international tax planning. The presentation will be made to tax attorneys and CPAs, and will cover both "outbound" and "inbound" transactions. More specifically, the presentation covers: 

 

  • U.S. income tax residency rules;

  • U.S. estate tax residency rules; 

  • Controlled foreign corporations (“CFCs”)

  • Deferral and anti-deferral rules under the subpart F regime and the PFIC regime

  • Foreign tax credits

  • FDAP

  • Rules related to U.S. trade or business and effectively connected income

  • Foreign Investment in Real Property Tax Act (“FIRPTA”)

  • Source of income issues

  • Income Tax Treaties 

 

 

More information about the presentation is provided at the BNA site, at the link below. 

 

Bloomberg BNA: Basics of International Tax Planning

 

 

IRS CIRCULAR 230 NOTICE: ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY HARLOWE & FALK LLP TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.