Sourcing U.S. and Foreign Income: Dividends, Service Income, Property Sales, Rents, and Income Tax Treaties
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide a comprehensive review of how income is sourced to the U.S. and other countries. Our authoritative panel will provide insights to help mitigate multi-country taxation and avoid improper classifications of income. They will explain the benefits available in particular income tax treaties and review the exceptions to the general rules for each class of income.
- Source of income rules: an overview
- Dividend income
- Service income
- Rents and royalties
- Sale of real property
- Sale of other property
- Other income
- Treaty exceptions
The panel will cover these and other vital issues:
- What are the exceptions to the general dividend income sourcing rules?
- How is service income apportioned between the U.S. and other countries
- What is the temporary presence exception and how is it applied?
- How is personal property, including trademarks and intangible assets, sourced?
Andre Benayoun, J.D.
Partner - Tax & Business Services
Mr. Benayoun is a Partner who specializes in consulting around international taxation for inbound and outbound... | Read More
Mr. Benayoun is a Partner who specializes in consulting around international taxation for inbound and outbound multinational corporations, S corporations, partnerships, and individuals and families.Close
Patrick J. McCormick, J.D., LL.M.
Culhane Meadows Haughian & Walsh
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.Close