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A comprehensive two-day introduction with live group instruction on the fundamental concepts of international taxation.
BENEFITS OF ATTENDING
• Learn the basic principles of international tax law and tax jurisdiction underlying international tax systems worldwide
• Find out the causes of double taxation and what methods are adopted to avoid it in different tax systems
• Discover 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
• Learn basic OECD arms-length transfer pricing principles and their application in resolving pricing and thin capitalization disputes
• Become familiar with the use of tax havens and anti-haven legislation
• Identify special cross-border issues involving indirect taxes, cross-border mergers and acquisitions and estate and gift taxes
• Attend this ADIT-specific course and prepare for the ADIT Paper l exam
WHY YOU SHOULD ATTEND
In today’s global tax environment, corporate tax professionals are
increasingly exposed to different tax laws in each country and must be
sensitive to differences in tax systems. Employers also need to be
confident that they have capable individuals who can see the big picture
and can resolve international tax problems using the latest tools and
resources. Tax practitioners involved in tax planning and compliance
must understand the broader international tax issues and the tools
available to avoid domestic or foreign double taxation. In addition,
more countries are increasing regulation of cross-border residents and
transactions, so your company or clients must be aware of the underlying
tax reporting responsibilities in structuring operations worldwide and
avoid noncompliance penalties and interest.
Bloomberg BNA is pleased to announce a course on the fundamentals of international taxation, which is designed to familiarize attendees with the key principles of tax systems worldwide. Principles of International Taxation will be taught by our experienced faculty of EU and U.S. tax accountants and attorneys, including ADIT recipients. Key topics, including tax jurisdiction and double taxation, tax treaty terminology and benefits, and transfer pricing and thin capitalization, will be covered in a comprehensive three-day format.
Attendees interested in enrolling in the ADIT (Advanced Degree in International Tax) program can use the materials in this course as preparation for the Paper l Exam on December 2016. A reading list for the course is available at the ADIT website (www.ADIT.org.uk).
WHO SHOULD ATTEND
This two-day course is designed as an introductory course on
general principles of international taxation. Materials in this course
can be applied in most countries including the United States. The course
is recommended for new and experienced tax accountants and attorneys
involved with multinational clients, which are doing business in
multiple taxing jurisdictions. Corporate tax directors, managers and
their staff will find this course is particularly useful if working with
tax systems in other countries.
This ADIT-specific course is designed to assist attendees in preparing for the Paper l exam offered by the CIOT in December 2016. For more information on ADIT, see www.ADIT.org.uk. ADIT allows tax practitioners to increase their knowledge of cross-border tax issues and enhance their professional skills. ADIT confers a professional international tax designation, in recognition of the time spent by applicants in attending, studying and researching international tax laws in the United States and other countries. No course prerequisites are required, but a reading list can be found on the ADIT website. www.ADIT.org.uk This program is transitional which is appropriate for newly admitted attorneys.
8:15 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
• History of international tax law
10:30 am Refreshment break
10:45 am Double Tax Treaties - Overview OECD Model Convention
• Format and structure of a DTC
• Applying provisions of DTCs
• Interpretation of DTCs
• Residence in DTCs
• Residual category of “other income"
12:30 pm Luncheon
1:15 pm Double Tax Treaties – Business Profits & Services
• Business profits
• Permanent establishments
2:30 pm Refreshment break
2:45 pm Double Tax Treaties – Employees, Directors and Individuals
• Independent personal services
• Dependent personal services
• Directors, officers, other functionaries
• Governmental employees
• Pensions and annuities
4:30 pm Seminar Adjourns for the Day
8:00 am Continental Breakfast
8:30 am Double Tax Treaties
• Dividends, interest and royalties
• Limitation of benefits
• Capital gains
9:45 am Refreshment break
10:00 am Double Tax Treaties (continued)
12:00 pm Luncheon
12:45 pm Overview and Examples of the Application of Double Tax Conventions
2:15 pm Refreshment break
2:30 pm International Developments
• Overview of adopted or proposed Base Erosion Profit Shifting (BEPS) and Exchange of information (EOI) initiatives by the OECD, EU and the US
5:00 pm Seminar Concludes
November 14 & 15, 2016
AMA Conference Center
1601 Broadway (at 48th and Broadway)
New York, NY 10019
Hotel accommodations are at your own discretion. We suggest the following:
319 West 48th Street
New York, NY 10036
Tel: (212) 245-7000
Novotel of New York
226 West 52nd Street
New York, NY 10019
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 firstname.lastname@example.org 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 email@example.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, complaints and cancellations, please contact us at 800.372.1033, or e-mail firstname.lastname@example.org.
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 email@example.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.
Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.
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