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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Tuesday, November 1, 2022

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This webinar will break down the terminology, filing requirements, and withholding rules for foreign inbound transactions for tax practitioners working with multinational individuals and businesses. Our panel of knowledgeable foreign tax experts will discuss effectively connected income (ECI), fixed, determinable, annual, or periodic (FDAP) income, Form 1040NR, and 1120-F for tax practitioners working in the international realm.

Faculty

Samantha Guis
Sax, LLP

Ms. Guis is a Tax Senior Manager in the International Tax Services Group, with nearly 10 years of experience in the areas of tax and accounting. She has experience in U.S. and international tax planning and compliance for U.S. and foreign high net worth individuals. Ms. Guis works with a variety of clients that are U.S. citizen and foreign individual living in both the United States and abroad.

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Matthew Halpern
STS-Int'l Senior Manager
BDO USA

Mr. Halpern is a Senior Manager in the International Tax Services group at BDO. With over 10 years of experience, he works with multinational companies on both their outbound and inbound tax planning as well as the various compliance aspects involved. Mr. Halpern has the skills to explain complex tax technical topics to Non-tax professionals and by educating his clients on the intricacies of the U.S. Technical Tax rules, they gain comfort in their business decisions. 





Mr. Halpern has worked extensively with companies in the professional services, information technology, consulting services, life-sciences and the manufacturing and distribution industries. His client base has significant international operations that face everyday challenges, including Subpart F, Global Intangible Low-Taxed Income (GILTI), Foreign Tax Credits and the Foreign-Derived Intangible Income deduction (FDII) at both the corporate and individual levels.





Additionally, Mr. Halpern understands the issues that are important to business enterprises with multinational activities, which includes foreign owned domestic businesses, outbound transfers of U.S. property, treaty jurisdictions and global expansion of the U.S. footprint. He understands the impact of U.S. tax compliance rules and requirements that may result from the effects of foreign transactions and structuring by U.S. taxpayers.

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Description

The reporting considerations for foreign inbound activity by foreign taxpayers in the U.S. are complex. To determine how income in the U.S. is taxed and what tax withholding is required, practitioners must first determine the type of income generated and then must understand the withholding and documentation requirements surrounding such income. Effectively connected income (“ECI”) is income generally connected with a U.S. trade or business. On the other hand, income that is not ECI and U.S. sourced may be fixed or determinable, annual, or periodic income which may be considered fixed or determinable, annual, or periodic income or (“FDAP”). FDAP income is generally subject a to 30 percent withholding tax unless an Income Tax Treaty or other income tax provision can apply to reduce the withholding tax rate.

Generally, Nonresidents with ECI should file Form 1040NR, U.S. Nonresident Alien Income Tax Return. Similarly, foreign corporations with ECI generally should file Form 1120-F, U.S. Income Tax Return of a Foreign Corporation. Both Nonresidents and Foreign corporation with U.S. withholding may want to file if an opportunity exists to obtain a refund of the withheld taxes. Often there are ways to mitigate or reduce U.S. withholding taxes at source, depending on Income Tax Treaties and other positions taken. Tax practitioners working with foreign taxpayers should understand basic terms, concepts, reporting and documentation requirements for foreign inbound transactions.

Listen as our international tax reporting professionals walk you through foreign inbound transactions, including U.S. withholding and reporting requirements.

Outline

  1. Foreign inbound reporting: introduction
  2. Effectively connected income (ECI)
  3. Fixed, determinable, annual, or periodic income (FDAP)
  4. Partnerships with non-U.S. owners
  5. Withholding requirements
  6. Non-resident tax returns: Form 1040NR
  7. Returns of foreign corporations: Form 1120F
  8. Other foreign inbound reporting considerations

Benefits

The panel will cover these and other key issues:

  • What is FDAP income, and how is it taxed in the U.S.?
  • Who is considered a nonresident alien and required to file form 1040NR?
  • What are the U.S. withholding obligations of withholding agents?
  • When is a foreign business considered to have a U.S. trade or business and ECI?

NASBA Details

 

Learning Objectives

After completing this course, you will be able to:

  • Recognize how the U.S. foreign tax reporting regime is structured.

  • Understand the requirements for reporting inbound activities.

  • Identify the reporting requirements of U.S. resident taxpayers and foreign individuals.

  • Determine who is required to file Form 1120-F.

  • Recognize reportable transactions with related parties that must be reported on Form 5472.

  • Establish when there is ECI and the tax consequences.

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years + business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of foreign tax reporting, resident aliens vs. non-residents, US investments owned by foreign persons, withholdings and withholding agents, individual filing requirements, effectively connected income (ECI), fixed or determinable annual or periodic income (FDAP),  inbound filing obligations, and sourcing rules; familiarity with Forms 1120-F and 5472 and FIRPTA.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).