Cross Border Finance
Author: William J. Seeger
| CPE Credit: |
1 hour for CPAs
1 hour Federal Tax Related for EAs and OTRPs
1 hour Federal Tax Law for CTEC |
This course is an essential for all practitioners who deal with cross-border tax compliance and planning issues. It is especially important today, as the IRS has aggressively increased scrutiny and enforcement activity in the international tax area.
Publication Date: October 2021
Designed For
Professionals in public practice and industry will benefit from this program. Business tax and finance executives, directors, managers and staff; CPAs; Enrolled Agents; tax preparers and staff; accountants, attorneys, and financial advisors who work with and advise businesses and individuals with cross-border operations, activities and issues.
Topics Covered
- Financial Transactions
- Debt Characterization
- Covered Population
- Intercompany Loans
- Financial Guarantees
- Loans/Guarantees
- Cash Pooling
- Hedging
- Captive Insurance
- Receivables
- Rates of Return
Learning Objectives
- Recognize how dispute resolution programs work with an emphasis on intercompany pricing
- Identify opportunities where dispute resolution planning can mitigate audit and tax risk
- Recognize the relevant steps to employ the essential requirements
- Differentiate which foreign tax credit is also referred to as the deemed paid credit
- Recognize and apply the formula for computing the foreign tax credit limitation
- Describe the arm's length principle
- Recognize which relevant factors a taxapayer must consider to determine the arm's length rate
- Describe a captive insurance company
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (1 hour)
Program Prerequisites
None
Advance Preparation
None
