Use of U.S. Income Tax Treaties by Corporations

Use of U.S. Income Tax Treaties by Corporations (7637019).jpg
Use of U.S. Income Tax Treaties by Corporations (7637019).jpg

Use of U.S. Income Tax Treaties by Corporations

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Use of U.S. Income Tax Treaties by Corporations

This basic to intermediate level webinar is designed for the corporate tax professional seeking an understanding of U.S. income tax treaties and how a domestic corporation with international operations and a foreign corporation with U.S. operations may benefit from them.  Learning Objectives:

  • Make suggestions on how to read an income tax treaty
  • Review the purposes of income tax treaties as an aid to interpretation
  • Determine the eligibility of a corporation for benefits under income tax treaties
  • Review qualifications for protection under the permanent establishment clause
  • Review the withholding tax reductions and exemptions for dividends, interest and royalties
  • Review the use of competent authority procedures
  • Review the impact of proposed changes to the U.S. Model Income Tax Treaty and the OECD Model under BEPS Actions 6 and 7
  • Review the compliance requirements for a foreign corporation to claim U.S. tax benefits under an applicable U.S. treaty

No CPE/CLE Credit Available

Presented by: William K. Norman is a Partner in the law firm of Ord & Norman in Los Angeles, California and is a Coordinator of its Private Client and International Business Transactions Departments.  He is also a member of the firm’s Tax Litigation and Controversy Group.  He is a Certified Specialist in Taxation Law.  In his practice, he focuses on the counseling of clients in cross border business transactions, cross border real estate investment structures, personal wealth planning for the multinational family, offshore voluntary disclosures, expatriations of U.S. citizens and green card holders, use of trusts by multinational families, and representation of taxpayers before the IRS and the Tax Court.  Mr. Norman received an A.B. degree in economics from the University of California at Berkeley, a J.D. degree from the University of California and an LL.M. (in taxation) degree from New York University School of Law.  He is a senior adjunct professor in the Graduate School of Taxation, Golden Gate University. He is immediate past chair of STEP-LA Branch.  He has appeared as a speaker and seminar leader at the USC Tax Institute and the New York University Tax Institute.  In June of 2008, the Taxation Section of the Los Angeles County Bar Association presented the Dana Latham Award to him in recognition of his outstanding contributions to the field of taxation.