BarbriSFCourseDetails
  • videocam Live Webinar with Live Q&A
  • calendar_month June 25, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

NIIT Relief and Income Tax Treaties: Recent Court Rulings, Foreign Tax Credit, Reporting

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$294.95
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Discount expires 6/11/26

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CLE
CPE
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About the Course

Introduction

This CLE/CPE webinar will provide tax professionals with an in-depth analysis of the net investment income tax (NIIT) relief under current U.S. tax law and the interplay with income tax treaties. The panel will discuss the recent court rulings and the potential for U.S. citizens to use foreign tax credits (FTC) to offset NIIT. The panel will also discuss key considerations and tax treaty provisions that tax counsel must master in structuring cross-border ownership structures and transactions.

Description

The NIIT, also known as the 3.8 percent Medicare tax, applies to the net investment income of individuals in upper-income brackets and is generally viewed as an alternative to employment taxes on earned income. However, the application of income tax treaty provisions as a mechanism to allow taxpayers certain tax savings is uncertain, resulting from recent court rulings that significantly impact the NIIT.

U.S. tax law imposes a 3.8 percent NIIT on the "net investment income" of certain U.S. taxpayers with income above certain thresholds. The NIIT applies to U.S. citizens or residents, trusts, and estates that have net investment income and income above those thresholds. The NIIT for individuals is 3.8 percent of the lesser of net investment income for the taxable year or the excess of the individual's modified adjusted gross income, over the threshold amount.

Listen as our panel discusses the recent court rulings and the potential for U.S. citizens to use FTCs to offset NIIT.

Presented By

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. Mr. McCormick is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • CPE credit is not available on recordings.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

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


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, June 25, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. NIIT basics

II. Understanding FTCs, NIIT, and tax treaties

III. Recent court cases; analysis and impact to taxpayers

IV. Guidance for seeking NIIT relief under treaty terms

V. Best practices and pitfalls to avoid for taxpayers

The panel will discuss these and other key issues:

  • What are the basics of NIIT and its application to certain income?
  • What is the interplay of NIIT with FTC and income tax treaties?
  • What are the key issues and opportunities stemming from recent court cases?
  • How can you obtain NIIT relief under treaty terms and potential challenges?

Learning Objectives

After completing this course, you will be able to:

  • Identify recent case law developments regarding NIIT relief
  • Recognize the basics of income tax treaties and NIIT application
  • Understand processes for seeking NIIT relief under a tax treaty


  • 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 transaction documents and partnership agreements, supervising other attorneys or accountants. Specific knowledge and understanding of foreign income tax rules, including U.S. tax disclosure and withholding requirements; familiarity with tax treaty structures and U.S. tax rules mitigating the impact of dual taxation on economic activities carried on by U.S. taxpayers in other countries and tax jurisdictions.

BARBRI, 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

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

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .