Bloomberg BNA: International Tax Planning Basics for Attorneys and CPAs. 

 

Bloomberg BNA recently requested that I present on the topic of International Tax planning to be presented to attorneys and CPAs. A description of the presentation is below. 

 

In an increasingly interconnected world, business and investments often span outside the home country of the client. The ability to spot issues and provide practical solutions is essential when consulting with clients with international ties. This presentation will cover both “inbound” issues related to foreign clients coming to the U.S., as well as “outbound” issues related to U.S. clients investing abroad, and will cover some basics of estate planning for international clients.

Key takeaways from this presentation will include understanding residency, and when a client is taxable as a “U.S. Person” for both income tax and estate tax purposes. Further, this presentation will cover international tax issues related to U.S. Persons investment abroad, including what constitutes a controlled foreign corporations (“CFCs”), deferral and anti-deferral rules under the subpart F regime and the PFIC regime, and foreign tax credits.

This presentation will also provide common “inbound” issues, including when a foreign client is taxable in the U.S., the rules under FDAP, and rules related to U.S. trade or business and effectively connected income. In addition, this presentation will cover common issues related to investment in real property by nonresidents within the U.S., including application of the Foreign Investment in Real Property Tax Act (“FIRPTA”), including common planning strategies.

Finally, this presentation will cover basic issues in the application of income tax treaties, taxability under a permanent establishment (“PE”), and common issues related to income sourcing.

Educational Objectives:
• Know how to spot common U.S. tax issues related to both “inbound” and “outbound” transactions. 
• Know the U.S. tax implications for a U.S. Person’s investment abroad 
• Recognize whether a non-resident is taxable in the U.S., and the potential tax exposure 
• Know the common planning techniques to help reduce or eliminate U.S. tax

Who would benefit most from attending this program?
Business & Tax Attorneys and CPAs with clients with international business activities or international investments.

 

The materials from the presentation can be found at the link below:

 

Bloomberg BNA: Basics of International Tax Planning for Attorneys and CPAs

 

 

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.