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Enjoy lunch and learn about international tax during this monthly webcast. Gain insights on how to better serve the needs of international tax clients by covering the basics as well as navigating through more complex topics. These webcasts are presented at noon.
Credits: CPE: 1, MCLE: 1, MCLE LS-TX: 1
Topics: Recognize potential holding structures for holding a foreign business, tax cost for each available structure and necessary paperwork for each structure
Topics: Identify Section 951A rules and filing requirements. Determine whether foreign income is susceptible to GILTI requirements.
Topics: Recognize the effects of Section 962 election and determine whether its election is beneficial in a variety of structures.
Topics: Identify when treaty elections are permitted. How to prepare Form 8833 to make the treaty election. When is it useful to make a treaty election? Making a treaty election to make yourself a nonresident of the USA.
Topics: Identify pros and cons for a variety of real estate holding structures. Recognize non-tax related issues for certain holding structures. Determine best holding structure based on company activities.
Topics: Identify the tax and business factors affecting foreign investor groups acquiring U.S. real estate. Review the investment structures that can be used for debt and equity investment in U.S. real estate.
Topics: Learn basic concepts about allocating assets between spouses. Identify what assets and liabilities are included in the net worth test. Understand valuation methods that can be applied to your assets. Learn strategies for reducing net worth to avoid being a covered expatriate.
Topics: Identify how an individual becomes a covered expatriate. Learn the four different ways that assets are taxed upon expatriation for covered expatriates. Identify timing problems and other issues that lead to high tax rates for covered expatriates. Understand how to prepare so that you can avoid tax timing problems and pay the lowest amount of tax possible.
Topics: Identify the Form 5472 filing requirements. Recognize what attribution rules apply and common situations in which Form 5472 is required because of attribution rules. Apply attribution rule concepts to prepare Form 5472. Recognize when a foreign corporation is engaged in a U.S. trade or business.