Unlocking Global Opportunities: An Introduction to Tax Treaties

This program, taught by Patrick J. McCormick of Offit Kurman, contextualizes the use of income tax treaties in the international tax area. The course begins with an overview of how the United States taxes nonresidents, both conceptually and under statutory rules. Mr. McCormick provides historical background on United States tax treaties, the ongoing relevance of the U.S. model treaty, and the interaction between statutory and treaty rules. The program then delves into specific treaty terms and where/how they are used, including compliance requirements for obtaining treaty benefits.

Understanding tax treaties is essential for businesses and individuals engaged in cross-border activities. These agreements between countries are designed to prevent double taxation, reduce tax barriers, and promote economic cooperation.

Webinar Objectives

• Introduction To Tax Treaties
• Nonresidents – Income Tax
• Background Considerations
• Nonresidents – United States Trade or Business Income
• FDAP Income
• Income Tax Treaties – Basic Structure
• Income Tax Treaties – Who Can Obtain Benefits?
• Tax Treaties – Common Provisions
• What Are Permanent Establishments?
• Nonresident Individuals - Transfer Taxes
• United States Transfer Taxes – Classification

Webinar Agenda

• Review historical background on U.S. tax treaties, the ongoing relevance, and interaction between statutory and treaty rules
• Discuss specific treaty terms and analyze where and how they are used
• Identify compliance requirements for obtaining treaty benefits
• Detailed Review of Non-Resident Income Tax
• Understand Fixed or Determinable Annual or Periodic Income

Webinar Highlights

• Prevent Double Taxation: Ensure that income isn’t taxed by both countries.
• Enhance Certainty: Provide clarity on tax obligations and rates.
• Encourage Investment: Foster a stable environment for international business.

Who Should Attend

• Finance Professional
• Accountants
• CPA's
• Business Owners
• Investors
• All Other Personnel Dealing With Internation Trade Or Workforce

Credit(s)

IRS CPE Credits: 1 Tax hour