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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, December 14, 2021

  • 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 provide background on treaty provisions, then review the Mexico-United States and Canada-United States income tax treaties in detail. The treaties are juxtaposed, allowing advisers to grasp standard components of modern and dated U.S. income tax treaties with other countries.

Faculty

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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Jorge San Martin
Partner
SMPS Legal

Mr. San Martín represents national and multinational clients in local and international tax matters regarding cross-border operations, investments and transactions. Additionally, he regularly provides clients with tax and business planning advice, including tax advice pertaining to mergers and acquisitions, as well as any corporate reorganization with particular focus on permanent establishments and other tax-related international matters. Mr. San Martín also provides advice involving structuring and planning of tax efficient structures, including the tax treatment of acquisitions and investments.

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Description

In working with nonresident taxpayers and U.S. tax ramifications, a functional understanding of income tax treaties is a prerequisite. The United States maintains various income tax treaties with other countries; each treaty has specific terms. While some level of uniformity exists under income tax treaties, specific terms--and resulting benefits--are subject to substantive variance between treaties.

There are distinct but common differences in the treaties with Canada and Mexico. While both treaties address double taxation and contain a saving clause, the former treaty is more modernized while the latter is not. Interpreting U.S. income tax treaties and their benefits for digitized business enterprises is crucial in today's environment.

Listen as our panel of international tax experts compares and contrasts two typical U.S. income tax treaties and explains how to identify the critical tax components of these agreements for advisers working with multinational taxpayers.

Outline

  1. U.S. income tax treaties: an introduction
  2. Common components
    1. Mexico
    2. Canada
  3. Key differences
    1. Mexico
    2. Canada
  4. Tips for analyzing U.S. income tax treaties
  5. New considerations for digital commerce

Benefits

The panel will cover these and other crucial issues:

  • How to analyze U.S. income tax treaties for key tax components
  • Applying income tax treaty benefits in a digital business environment
  • Commonalities found in the U.S. income tax treaties with Canada, Mexico, and other countries
  • Distinct differences in the U.S. income tax treaties with Canada and Mexico

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify commonalities between the U.S. income tax treaties with Canada and Mexico
  • Decide why dated treaties create tax conundrums
  • Determine how to analyze a typical tax treaty for tax consequences
  • Ascertain new considerations for internet sales

  • 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).