Limitation on Benefits Provisions: Analyzing Article 22, U.S. Model Treaty and LOB in Specific U.S. Tax Treaties
Meeting Residency Requirements, Withstanding IRS Challenges
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will take a comprehensive look at the limitation on benefits (LOB) provisions in U.S. income tax treaties. Our panel of prominent international tax attorneys will review the purpose of LOB clauses in these treaties and discuss meeting residency requirements using the U.S. Model Treaty as a guide. They will also analyze these provisions in U.S. income tax treaties with specific countries.
Outline
- LOB provisions in treaties: an introduction
- LOB definition and purpose
- U.S. Model Treaty, Article 22
- Typical compliance tests
- LOB examples from specific countries
- Withstanding IRS challenges
Benefits
The panel will cover these and other critical issues:
- Utilizing the LOB provisions to obtain specific treaty benefits
- Applying LOB criteria in specific countries based on the relative U.S. income tax treaty
- The state of the current IRS initiative regarding nonresidents' eligibility for treaty benefits
- Qualifying for residency under Paragraph 1 of the U.S. Model Income Tax Treaty
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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