International Cross Border Transactions

Author: Allison McLeod

Join Allison McLeod, CPA, us for an introductory course in international cross border transactions. We will discuss typical situations in which a cross-border transaction arises, and how a taxpayer can utilize the rules to potentially decrease an entities effective tax rate. Other issues, such as documentation and IRS audit risk will also be covered. These rules will be illustrated by a hypothetical US-Canada transaction.

Publication Date: September 2021

Designed For
Ideal for CPAs, EAs and other tax preparers.

Topics Covered

• U.S. Entity with Foreign Operations
• Foreign Corporations with Us Operations
• Royalties and License Fees
• Minimizing Effective Tax Rate
• Inversions
• Cross Border Financing
• Resolving Conflicts
• Case Study- Caterpillar

Learning Objectives

• Identify a cross border transaction and be able to discuss potential implications
• Describe potential audit risks involved with cross border transactions
• Recognize how to explain the role of competent authority, advanced pricing agreements and other alternative methods in reducing audit risk
• Identify the types of contemporaneous documentation needed
• Recognize and apply these principles in order to decrease and entity's effective tax rate
• Identify under which provision dividends received from foreign subsidiaries may be deducted under
• Identify the situation where U.S. shareholders are not taxed on a foreign corporation's earnings until repatriated as dividends to shareholders
• Identify the U.S. source investment income withholding rate, regarding the taxation of a foreign corporation's U.S. trade or business income
• Identify a proactive method of minimizing the effective tax rate
• Recognize when the new §163(j) is effective for tax years begins

Level
Basic

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None