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Taxation Advanced Issues

42,500.00

Format Online
NASBA Field of Study Taxes
Level Basic
CPE Credits 13.5
Availability 1 year
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Specs

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Description

This Certificate course will teach you:

  • To understand the complexities of international taxation.
  • To handle complex tax issues such as transfer pricing, tax treaties and corporate formations.

Course Details:

 

  • This series of five courses include:
    • S. Transfer Pricing and Global BEPS
    • S. Tax Treaties
    • International Tax Transactions I
    • International Tax Transactions II
    • Corporate formations, reorganization, acquisitions, and liquidations

Key Topics

  • Section 351
  • Transfer Pricing
  • Permanent establishment
  • Tax Treaties
  • BEPS overview
  • Reorganizations
  • Stock acquisitions
  • Corporate formation
  • Inversions

Learning Outcomes

  • Identify the accepted transfer pricing methods and when it’s appropriate to use them
  • Recall how U.S. tax treaties determine U.S. tax residency and how it impacts eligibility under the treaty
  • Distinguish how hybrid entities are treated under U.S. income tax treaties
  • Assess whether a U.S. person’s transfer of property to a foreign corporation should generally qualify for non-recognition treatment under section 351
  • Assess whether a reorganization or restructuring may qualify as an “inversion” subject to the rules of section 7874

 

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