Overview

Build a solid foundation.

This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation. This course can be purchased individually or as part of the U.S. International Tax: Advanced Issues bundle. You must purchase the bundle to earn the digital badge.

The CPE self-study course focuses on U.S. tax treaties. This is an overview of the U.S. tax treaty definitions and their impact on permanent establishment, business profits, tax residency, hybrid entities, Fixed, Determinable, Annual or Periodic (FDAP) income, limitation on benefits (LOB) clauses, income resourcing, and foreign tax credits.

Highlights

Key Topics

• Permanent establishment
• Business profits
• Tax residency
• Hybrid entities
• FDAP income
• LOB clauses
• Income resourcing
• Foreign tax credits

Prerequisites

None

Objectives

Learning Outcomes

• Identify when a permanent establishment exists
• Determine the attributable business profits to a permanent establishment
• Recall how U.S. tax treaties determine U.S. tax residency and how it impacts eligibility under the treaty
• Distinguish how hybrid entities are treated under U.S. income tax treaties
• Determine the impact a US income tax treaty has on withholding taxes on FDAP
• Apply the appropriate LOB clause to determine eligibility under a U.S. tax treaty
• Identify the mechanisms for tax dispute resolution