All registrants of this webinar will receive a complimentary copy of Bloomberg BNA Portfolio 6480, The Branch-Related Taxes of Section 884, written by speaker Peter J. Connors (a $400 value).

Foreign corporations entering into the U.S. through corporations or pass-through entities must be familiar with the mechanics of the branch profits tax.

This new practical webinar from Bloomberg BNA, The Branch Related Taxes, presented by Peter Connors, provides advisors with the latest techniques and opportunities, and potential pitfalls.

During this live webinar, Connors will cover:

• An overview of the rules applicable to determining effectively connected income.
• An overview of the branch profits tax.
• The mechanics of the branch profits tax.
• The mechanics of calculation of interest under Reg. §.1882-5.
• The mechanics of excess interest calculation.
• The impact of the OECD Model on the branch profits tax calculation.
• Withholding taxes and related treaty issues.
• Hybrid Entities and how they are affected by the branch profits rules.

Educational Objectives

• Understand the branch profits tax
• Understand the calculation of interest expense under Reg. §1. 882-5
• Understand the application of treaties under the branch profits taxes.
• Understand the withholding tax issues.
• Become conversant with the available elections under the branch profits tax.

Who Should Attend?

• Tax Directors of foreign corporations with US entities
• CFOs
• Group Tax Directors
• Chief Accounting Officers
• Legal practitioners in large and mid-size law firms

Prerequisite: None
Level: Intermediate to Advanced
Delivery method: Group Interactive Live
Recommended CPE credit: 1.5 credits 

Peter J. Connors, Orrick, Herrington & Sutcliffe, LLP