Corporate Transparency Act: Reporting Beneficial Ownership to FinCEN, Filing Requirements...
October 18, 2023 • CPE, EA • CPE On-Demand, Download
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This webinar will review the Corporate Transparency Act and its beneficial ownership reporting requirements. Our panel of astute tax professionals will walk you through the key definitions and the new reporting requirements and offer suggestions on complying with the Act for companies, trusts, and i...
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Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Incom...
December 19, 2023 • CPE, EA • CPE On-Demand, Download
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This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and nonresidential rentals, and properly reporting rental income and expenses with a...
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Limitation on Benefits Provisions: Analyzing Article 22, U.S. Model Treaty and LOB in Spec...
Meeting Residency Requirements, Withstanding IRS Challenges
February 5, 2024 • CPE, EA • CPE On-Demand, Download
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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 a...
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Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Incom...
March 21, 2024 • CPE, EA • CPE On-Demand, Download
This program is included with the
Strafford CPE Pass.
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This program is included with the
Strafford CPE+ Pass.
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Strafford All-Access Pass.
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This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and nonresidential rentals, and properly reporting rental income and expenses with a...
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Calculating and Reporting Foreign E&P: Categorizing PTEP, Form 5471 Schedules H, P & R, Fo...
January 16, 2024 • CPE, EA • CPE On-Demand, Download
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This course will discuss the complications surrounding the determination of foreign earnings and profits (E&P) for controlled foreign corporations (CFCs). Our panel of foreign tax experts will discuss the complexities of the related calculations, including categorizing income, handling retroactive a...
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Foreign Entity Selection and Taxation: Avoiding Tax and Reporting Pitfalls of Foreign Stru...
Planning for U.S. Owners of Offshore Businesses, Treatment of Foreign Trust...
September 28, 2023 • CLE, CPE, EA • CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of the tax and operational impacts of foreign entity selection for individuals owning controlling interests in international businesses. The panelist will discuss the tax issues that arise in foreign entity selection, wit...
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U.S.-Australia Tax Issues for Dual Status Taxpayers: Tax Planning and Compliance Requireme...
October 17, 2023 • CLE, CPE, EA • CLE On-Demand, Download
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This CLE/CPE webinar will provide estate planners with a comprehensive guide to tax planning challenges and opportunities for clients who have a tax presence in both the U.S. and Australia. The panel will discuss the U.S. tax law and treaty provisions that govern tax and fiduciary rules in both Aust...
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Applying the Saving Clause and Exceptions in U.S. Income Tax Treaties
September 7, 2023 • CPE, EA • CPE On-Demand, Download
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This webinar will discuss the application of the saving clause in U.S. international income tax treaties. Our panel of foreign tax matter experts will identify the saving clause in U.S. income tax treaties, analyze saving clause exceptions, and provide examples of the application of the saving claus...
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Nonresident Tax Issues: ECI, Structures for Holding U.S. Assets, Treaty Benefits, Estate a...
July 6, 2023 • CPE, EA • CPE On-Demand, Download
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This course will provide tax practitioners working with U.S. nonresident aliens (NRAs) with practical steps to minimize U.S. taxes for these U.S. taxpayers. The panelists will cover the rules for federal income, estate, and gift taxation of nonresidents and provide concrete advice on mitigating thes...
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IRC 7701 Check-the-Box Elections for Foreign Pass-Through Entities: Structuring Hybrid Ent...
Lowering U.S. Income Tax on Income From Eligible Foreign Entities by Electi...
June 6, 2023 • CLE, CPE, EA • CLE On-Demand, Download
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This CLE/CPE webinar will provide tax advisers with guidance on the advantages and pitfalls of using the "check the box" election for foreign LLCs and disregarded entities. The panel will discuss the tax impact of specific elections of income from foreign disregarded entities and outline tax timing...
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Canada-U.S. Estate and Gift Tax Planning: Utilizing Canada-U.S. Income Tax Treaty Provisio...
April 18, 2023 • CPE, EA • CPE On-Demand, Download
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This webinar will explain the transfer taxes paid in Canada and the U.S. by residents of the U.S. and/or Canada. Our panel of foreign tax experts will discuss specific articles in the Canada-U.S. Income Tax Treaty and provide examples of how these can be applied to mitigate estate and gift taxes pai...
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Foreign Financial Institution Reporting: FFI Agreement, Issues for U.S. Taxpayers, Due Dil...
February 9, 2023 • CLE, CPE, EA • CLE On-Demand, Download
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This CLE/CPE course will provide tax counsel and advisers with a detailed guide to preparing and filing a foreign financial institution (FFI) agreement. The panel will describe the FFI designation in depth, outline the due diligence and reporting requirements of a participating FFI, and discuss the...
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Classifying Foreign Entity Structures for U.S. Taxation: U.S. Reporting Requirements
Identifying Canada, Switzerland, the United Kingdom, and Other Countries' C...
December 8, 2022 • CPE, EA • CPE On-Demand, Download
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This webinar will identify the most frequent foreign entity structures encountered by U.S. international tax practitioners and their U.S. reporting requirements. Our panel of astute foreign tax professionals will divulge how these structures correspond with U.S. entity reporting structures, how they...
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International Private Client Issues for Non-U.S. Residents: Serving High Net Worth Foreign...
Foreign vs. Domestic Drop-Off Trusts, Working With Family Offices, Multi-Ju...
October 5, 2022 • CPE, EA • CPE On-Demand, Download
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Strafford CPE Pass.
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This course will provide advisors with a practical guide to the planning opportunities and potential tax pitfalls in providing private client services (PCS) for high net worth nonresident clients with U.S. tax presence. The panel will go beyond the basics to detail intricate strategies for minimizin...
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Branch Profits Tax: Form 1120-F Reporting, Identifying Trade or Business, Determining Trea...
August 30, 2022 • CPE, EA • Download
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This course will explain the nuances of branch profits tax, including what entities are subject to this additional tax, how U.S. effectively connected income, dividend equivalent amounts, and the change in U.S. net equity is determined, and the effect of U.S. income tax treaties on the branch profit...
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International Cryptocurrency Tax Compliance Challenges: Information and Income Tax Reporti...
July 12, 2022 • CPE, EA • CPE On-Demand, Download
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This webinar will discuss the information and income tax reporting obligations for individuals and businesses owning cryptocurrency. Our panel of foreign tax veterans will discuss the diverse treatment of digital assets in the U.S. and abroad, provide insights and advice on meeting tax and disclosur...
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Willful FBAR Violations: Distinguishing Willful and Nonwillful, Relevant Factors, Mitigati...
June 21, 2022 • CPE, EA • Download
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This webinar will examine the most recent and notable cases and guidance surrounding FBAR violations. Our astute panel will cover the factors differentiating willful and nonwillful violations, what constitutes willful blindness, enforcement measures, and steps taxpayers can take to mitigate and avoi...
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Interpreting Tax Treaties: Tax-Free Interest, Foreign Tax Credits and Form 8833
May 31, 2022 • CPE, EA • CPE On-Demand, Download
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This course will provide tax advisers, professionals, and preparers with a solid overview and explanation of key income tax treaty provisions needed to determine whether their clients may take treaty-based return positions. The panel will discuss income tax treaties that exist between the U.S. and o...
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Accidental Americans: Remedying Noncompliance, IRS Streamlined Procedures, Relinquishing a...
May 3, 2022 • CPE, EA • Download
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This webinar will explain which former U.S. residents, with no or insignificant ties to the U.S., may be subject to U.S. tax and information return reporting requirements. Our panel of foreign tax experts will discuss required filing and reporting requirements, using IRS' streamlined procedures to b...
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Canada and Mexico Income Tax Treaties: Contrasting and Analyzing Two Typical U.S. Treaties
December 14, 2021 • CPE, EA • CPE On-Demand, Download
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This webinar will provide background on treaty provisions, then review the Mexico-United States and Canada-United States income tax treaties in detail. The treaties are juxtaposed, allowing advisers to grasp standard components of modern and dated U.S. income tax treaties with other countries.
D...
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Pre-Immigration Income Tax Strategies and Nuances for First Year Tax Filing
September 28, 2021 • CPE, EA • Download
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This course will explain tax strategies, caveats, and considerations for nonresidents to reside in the U.S. or become U.S citizens. Our panel of foreign tax experts will discuss specific strategies, including basis step-up options, drop-off trusts, income acceleration, manipulating tax rates, and ot...
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Tax Challenges of Multinational Employment Benefits: RSUs, Stock Options, Deferred Compens...
August 10, 2021 • CPE, EA • Download
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This course will explain the taxation of multinational benefits for residents and nonresidents, including RSUs, stock options, retirement plans, and deferred compensation. Our panel will explain the tax considerations of these perks to lessen the overall tax burden for taxpayers subject to taxation...
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Tax Considerations of Repatriation: Previously Taxed E&P, Non-PTEP, Return of Capital, Mul...
June 8, 2021 • CPE, EA • Download
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This course will cover repatriation issues for multinational taxpayers. Our panel of foreign tax experts will examine distributions of E&P from PTEP, non-PTEP, and the return of basis and explain the tax considerations and benefits available for each distribution type.
Description
Before the 201...
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U.S.-European Union Dual Taxation Issues: Residency Determinations, Treaty Benefits, Digit...
June 3, 2021 • CPE, EA • Download
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This course will cover income tax treaties with several European countries in detail. It will examine the specifics and nuances of U.S. income tax treaties with France, Germany, Portugal, Spain, and other European countries to minimize taxes and secure benefits offered for taxpayers with dual filing...
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Foreign Investment in U.S. Real Estate: Reporting and Avoiding Withholding, Holding Struct...
February 3, 2021 • CPE, EA • CPE On-Demand, Download
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This course will explain the complexities of taxation and withholding on foreign investment in U.S. real property. Our panel of multinational tax veterans will focus on strategies to minimize taxation of these properties--whether held individually or through an entity--for tax practitioners working...
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