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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Corporate Tax

Date & Time
  • event Date

    Monday, November 25, 2024

  • 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).

$247.00
CPE
ALL

This webinar will identify the most frequent foreign entity structures encountered by U.S. international tax practitioners and their U.S. reporting requirements. Our panel of astute foreign tax professionals will divulge how these structures correspond with U.S. entity reporting structures, how they are reported and taxed in the U.S., and when a check-the-box election could be relative and beneficial.

Faculty

C. Edward Kennedy
Managing Director
C Edward Kennedy Jr, PC

Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Mr. Kennedy has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm. He is a frequent speaker in the areas of international tax compliance and reporting obligations U.S. information reporting requirements for foreign assets and foreign entities, U.S. tax implications of foreign pension and social security plans, and U.S. income and social tax treaty planning. Mr. Kennedy is a member of the Texas Bar and is licensed as a certified accountant in Georgia and Texas. He has a B.A. from Furman University and a J.D. from Vanderbilt University School of Law.

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Patrick J. McCormick
Partner
Rimon, P.C.

Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.

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Description

There are at least eight types of entities in the U.K.: public limited companies, private company limited by shares, and Royal Charters are included among these. Structure choices in Switzerland include Aktiengesellschaft (AG), public limited company (SG) corporations, and joint stock companies. The foreign entity types do not always correlate with U.S. entity classifications, including corporations, partnerships, LLCs, and sole proprietorships.

There are default U.S. classifications for entities depending on the number of owners and whether owners have limited liability. Some foreign entities are eligible to elect their status on Form 8832 and choose whether to be treated as a partnership or corporation. How an entity is treated in the U.S. is a critical determination. This determines the entity's reporting obligations, how distributions are taxed, and its withholding obligations. Tax professionals working with multinational taxpayers need to be able to readily identify common overseas entity structures and how these could be taxed in the United States.

Listen as our panel of international tax attorneys details common foreign country structures and their reporting and tax obligations in the United States.

Outline

  1. Identifying and reporting foreign entities in the U.S.
  2. Why it matters
    1. Dividends and distributions
    2. Withholding
    3. Other considerations
  3. U.S. default classification rules
  4. Check-the-box elections
  5. U.S. reporting requirements
  6. Other country entity types
    1. United Kingdom
    2. Canada
    3. Germany
    4. Australia and New Zealand

Benefits

The panel will cover these and other critical issues:

  • How common Canadian entities are reported and taxed in the U.S.
  • How a foreign entity's U.S. classification affects the taxation of distributions to its owners
  • When a foreign entity is eligible for a check-the-box election
  • How limited liability of owners affects U.S. tax status

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify common foreign entity structures
  • Determine how entity structure affects the taxation of payments made to owners
  • Decide how common Canadian business types are taxed in the U.S.
  • Ascertain when a check-the-box election could benefit a foreign entity

  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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).