Inbound Transactions and Federal Tax: Compliance Issues With 1120-F, 8833 and Other Forms

Tackling Protective 1120-Fs, Calculation of ECI and FDAP, Exemptions and Other Challenges

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

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Conducted on Wednesday, December 5, 2012

Recorded event now available

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Course Materials

This program qualifies for CPE and CFP continuing education credits.

This teleconference will provide advisors and tax professionals with a review of the essential aspects of taxable income in the U.S. for foreign taxpayers, and explore complications that often arise in preparing the related IRS forms and schedules.


Many tax professionals must become familiar with the complex, fact-specific requirements in federal tax law affecting inbound transactions involving foreign businesses and individuals, leading up to filings of Form 1120-F, a protective Form 1120-F, Form 8833, and other federal forms and schedules.

You need to grasp fundamentals such as U.S. business nexus, income effectively connected to a U.S. trade or business (ECI), and income that is fixed, determinable, annual or periodic (FDAP). Those determinations, calculations and allocations, along with U.S. tax treaties, guide choice and preparation of forms.

An explanation of how these concepts translate into practical decisions, and a discussion of the more problematic aspects of related forms, will help prepare you to handle tax compliance on inbound transactions more confidently and completely.

Listen as our panel of tax advisors analyzes the critical aspects of U.S. taxation of inbound transactions in a practical context for preparing IRS forms.



  1. Overview of key concepts
    1. U.S. trade or business
    2. U.S.-sourced income
    3. ECI and FDAP
    4. Disposition of USRPI
    5. Tax treaties
  2. Issues to anticipate with U.S. forms
    1. 1120-F, standard and preventive
    2. 8833


The panel will address these and other on-point topics:

  • Key concepts such as source of income rules, U.S. trade or business issues, ECI basics including FIRPTA, and branch profits tax.
  • Industry or activity fact patterns such as cyberspace activities or U.S. marketing and sales function, that affect a decision on whether to prepare a form for inbound investment.
  • U.S. business activity of partnerships and U.S. corporate subsidiary "blocker" issues, and their impact on the decision on filing forms.
  • Issues that arise when preparing forms such as 1120-F, 8833 or 5472.

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


Sams, James
James K. Sams
Principal, International Corporate Tax

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

Juan Carlos Ferrucho
Juan Carlos Ferrucho

Managing Director
Alvarez & Marsal Taxand

He works mainly with U.S. multi-nationals and foreign public and privately-held companies on complex operations on...  |  Read More

Kimberlee S. Phelan
Kimberlee S. Phelan
Tax Services Partner

She has more than 15 years of tax and accounting experience at national and regional accounting firms. Her work...  |  Read More

Carola Knoll
Carola Knoll
International Tax Manager

She has more than 20 years of experience with international tax specializing in expatriate and foreign national...  |  Read More

Silvia Flores
Silvia Flores
Senior Director
Alvarez & Marsal Taxand

She works primarily with public and closely held businessses on inbound and outbound international tax consulting and...  |  Read More

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