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Principles of International Tax


November 18 - 20, 2013
New York, NY
Product Code: TMC127

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A comprehensive three-day introduction with live group instruction on the fundamental concepts of international taxation.

Course Level: Basic Delivery Method: Live Group

LEARNING OBJECTIVES


After attending this event, participants will be able to:
• Describe the basic principles of international tax law and tax jurisdiction underlying international tax systems worldwide
• List the causes of double taxation and what methods are adopted to avoid it in different tax systems
• Discuss the history of tax treaty legislation and differences between the OECD and UN Model Treaty
• Understand key Treaty terminology and how to obtain withholding tax benefits while avoiding limitations on benefits (LOB) provisions basic OECD arms-length transfer pricing principles and their application in resolving pricing and thin capitalization disputes
• Discuss the use of tax havens and anti-haven legislation
• Identify special cross-border issues involving indirect taxes, crossborder mergers and acquisitions and estate and gift taxes

PREREQUISITES


There are no prerequisites for attending this program.


SUBSTITUTIONS, CANCELLATIONS & COMPLAINTS


If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution.

To request a transfer, contact customercare@bna.com with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event. Cancellations must be made in writing to customercare@bna.com more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted
if notice is received fewer than 5 business days before the event.

For more information regarding administrative policies, such as complaints and cancellations, please contact us at 800.372.1033, or e-mail customercare@bna.com.

New York, NY - Bloomberg LP
731 Lexington Ave
New York, NY 10022
Tel: 212.318.2000

DAY 1

 

8:00 am Registration and Continental Breakfast


8:45 am Welcome and Introduction 

9:00 am Basic Principles
• Basic principles of international tax law:
• Jurisdiction to tax
• Taxes and tax systems
• State practice in exercising tax jurisdiction
• Limits to tax jurisdiction
• Causes of international double taxation
• Methods of relief from International double taxation
• Private international law and taxation
• History of international tax law

Break for Refreshments at 10:30 am

12:30 pm Luncheon

1:45 pm Double Tax Conventions
• DTCs and domestic law
• DTCs and EC law
• Format and structure of a DTC
• Applying provisions of DTCs
• Interpretation of DTCs
• Residence in DTCs
• Permanent establishments
• Attribution of profits
• DTCs and electronic commerce
• DTC provisions relating to individuals

Break for Refreshments at 3:00 pm

5:00 pm Meeting Adjourns for the Day

DAY 2


8:00 am Continental Breakfast

9:00 am Double Tax Conventions (continued)
• Dividends, interest and royalties
• Capital gains
• Relevance of “other income “ article
• Methods of elimination of double taxation
• Non-discrimination
• Limitation of benefits

Break for Refreshments at 10:15 am

12:30 pm Luncheon

1:30 pm Transfer Pricing
• The arm’s length principle
• The OECD Guidelines
• Art 9, Model DTC
• Dispute resolution in DTCS
• Advance pricing agreements

Break for Refreshments at 3:00 pm

4:45 pm Meeting Adjourns for the Day

DAY 3


8:00 am Continental Breakfast

8:30 am Tax Havens and Anti-Haven Legislation
• Identification of tax havens
• OECD initiatives 
• Anti-haven legislation
• Anti-haven legislation and DTCs
• Anti-haven legislation and the EC
• Money laundering

Break for Refreshments at 10:15 am

12:30 pm Luncheon

1:30 pm Thin Capitalization and Other Topics
• Thin capitalization
• Exchange of information
• Indirect taxes
• Cross border mergers
• Estate and gift taxes

Break for Refreshments at 3:00 pm

4:45 pm Review and Close

EDUCATIONAL COURSE CREDIT


UP TO 24 CPE CREDIT HOURS AVAILABLE

Bloomberg BNA is registered with the National Association of the State Boards of Accountancy as a sponsor of continuing professional education on the National Registry of CPE sponsors. State Boards of Accountancy have final authority on the acceptance of individual courses. Complaints regarding registered sponsors may be addressed to NASBA, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417.

UP TO 24 CLE CREDIT HOURS AVAILABLE

Bloomberg BNA will apply for continuing legal education credits in any state or jurisdiction where available. For more information, please contact Bloomberg BNA customer service at 800.372.1033 and ask to speak to the CLE Accreditations Coordinator, or email us at accreditations@bna.com .

HARDSHIP POLICY

Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program.

If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at accreditations@bna.com. Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.