Branch Profits Tax: Form 1120-F Reporting, Identifying Trade or Business, Determining Treaty Benefits
Recording of a 110-minute CPE webinar with Q&A
This course will explain the nuances of branch profits tax, including what entities are subject to this additional tax, how U.S. effectively connected income, dividend equivalent amounts, and the change in U.S. net equity is determined, and the effect of U.S. income tax treaties on the branch profits tax rate.
Outline
- Branch profits tax: introduction
- Foreign corporations
- U.S. trade or business
- Effectively connected income
- Income tax treaties
- Calculating the tax
- Reporting the tax
- Special rules and exceptions
- Best practices
Benefits
The panel will cover these and other key issues:
- Determining when a U.S. branch is subject to the additional branch profits tax
- Identifying branch profits provisions in specific treaties
- Reporting the tax on Form 1120-F, Schedules II and III
- Determining the change in U.S. net equity
- When is a branch considered engaged in a U.S. trade or business?
Faculty
C. Edward (Ed) Kennedy, Jr., CPA, JD
Managing Director
C Edward Kennedy Jr
Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing... | Read More
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, J.D., LL.M.
Founder/Managing Partner
McCormick Tax
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.
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