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
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.
Overview of key concepts
- U.S. trade or business
- U.S.-sourced income
- ECI and FDAP
- Disposition of USRPI
- Tax treaties
Issues to anticipate with U.S. forms
- 1120-F, standard and preventive
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.
James K. Sams
Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical... | Read More
Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical assistance and tax consulting to clients on inbound and outbound tax issues. He previously served in several roles with the IRS Office of Chief Counsel.Close
Juan Carlos Ferrucho
Alvarez & Marsal Taxand
He works mainly with U.S. multi-nationals and foreign public and privately-held companies on complex operations on... | Read More
He works mainly with U.S. multi-nationals and foreign public and privately-held companies on complex operations on complex cross-border business transactions such as M&A and repatriation. He has a dozen years of experience in public accounting and law.Close
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
She has more than 15 years of tax and accounting experience at national and regional accounting firms. Her work emphasizes inbound and outbound international structuring, corporate tax research and planning, individual tax and executive compensation planning.Close
International Tax Manager
She has more than 20 years of experience with international tax specializing in expatriate and foreign national... | Read More
She has more than 20 years of experience with international tax specializing in expatriate and foreign national taxation and information reporting including PFICs, CFCs, foreign partnerships and FBAR forms. She has managed several offshore voluntary disclosure engagements.Close
Alvarez & Marsal Taxand
She works primarily with public and closely held businessses on inbound and outbound international tax consulting... | Read More
She works primarily with public and closely held businessses on inbound and outbound international tax consulting and compliance. She spends considerable time on cross-border acquisitions and investments, dispositions and restructurings, and tax-efficient financing structures.Close