Branch Profits Tax: Compliance and Planning from the Ground Up

Navigating the Tax Landscape for Foreign Businesses Operating in the U.S.

Recording of a 110-minute CPE webinar with Q&A


Conducted on Thursday, May 2, 2013

Recorded event now available

or call 1-800-926-7926
Program Materials

This teleconference will give tax advisors and federal tax professionals a detailed review of the branch profits tax, reported on Form 1120F. The panel will also cover other tax issues imposed on inbound activities of foreign businesses that are involved in a U.S. trade or business.

Description

The decision by a non-US person to do business in the US through a branch versus a US corporate subsidiary is heavily dependent on understanding the consequences of the branch profits tax provisions.  Tax advisors must fully grasp the implications of these provisions and the impact of a non-US taxpayer’s decisions on the form of investment in the US.

More particularly, foreign branches with operations in the U.S are potentially subject to a hefty branch profits tax of 30% on deemed withdrawals from the branch, unless reduced by treaty. There are potentially complex issues arising from the determination of the tax base on which this computation is made and the timing of imposition of the tax on the earnings of the branch.  In addition, a 30% tax may be imposed on interest expense claimed by the branch against its US business income, under the so-called branch level interest provisions.

Listen as our group of experienced tax advisors provides a detailed review of the branch profits tax, Form 1120F and other tax issues relating to U.S. inbound activities of foreign companies.

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Outline

  1. Mechanics of the branch profits tax
  2. Determining taxable income
  3. Structuring U.S. activities
  4. Tax treaties
  5. Tax controversy

Benefits

The panel will explore these and other relevant issues:

  • Understanding the mechanics of the branch profits tax
  • Understanding the mechanics of the branch level interest tax
  • Consideration of the application of tax treaties
  • Resulting impact on planning for US-inbound activities of foreign persons

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.

Faculty

James K. Sams
James K. Sams
Principal
KPMG

Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical...  |  Read More

Misey, Robert
Robert J. Misey, Jr.

Shareholder
Reinhart Boerner Van Deuren

Mr. Misey is attached to the firm's Tax and Business Law Practices, and chairs its International Practice. He...  |  Read More

Douglas Holland
Douglas Holland
Senior Manager
KPMG

He is assigned to the International Corporate Services Group in the firm's Washington National Tax Practice. He...  |  Read More

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