The Introduction to International Taxation Conference provides a broad-based foundation in the federal income taxation of cross-border (both “inbound” and “outbound”) transactions and circumstances. Key topics include:
- The relationship between income tax treaties and the Internal Revenue Code generally, including the standard subject-matter coverage of such treaties, and when and how treaties override Code provisions
- The basics of transfer pricing, including a comparison of US transfer pricing rules to those of other countries, and the mechanisms for addressing conflicts
- The nature and application of withholding taxes and other “toll charges” on the movement of money and property across borders
- The foreign tax credit and anti-deferral rules affecting controlled foreign corporations and passive foreign investment companies
- US compliance and reporting issues faced as a result of doing business globally