NIIT Relief and Income Tax Treaties: Recent Court Ruling in Christensen v. U.S., Foreign Tax Credit, Reporting
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax professionals with an in-depth analysis of the net investment income tax (NIIT) relief under current U.S. tax law and the interplay with income tax treaties. The panel will discuss the recent court ruling in Christensen v. United States and the IRS' appeal of such ruling, and the potential for U.S. citizens to use foreign tax credits (FTC) to offset NIIT. The panel will also discuss key considerations and tax treaty provisions that tax counsel must master in structuring cross-border ownership structures and transactions.
Outline
- NIIT basics
- Understanding FTCs, NIIT, and tax treaties
- Christensen v. United States; analysis and impact to taxpayers
- Guidance for seeking NIIT relief under treaty terms
- Best practices and pitfalls to avoid for taxpayers
Benefits
The panel will discuss these and other key issues:
- What are the basics of NIIT and its application to certain income?
- What is the interplay of NIIT with FTC and income tax treaties?
- What are the key issues and opportunities stemming from Christensen v. United States?
- How can you obtain NIIT relief under treaty terms and potential challenges?
Faculty
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.
CloseCannot Attend June 11?
Early Discount (through 05/17/24)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.