eLearning

The Branch Related Taxes

Price: $224 eLearning

FULFILL ALL YOUR CONTINUING EDUCATION CREDITS FOR $399

Sign up today for an entire year of unlimited access to relevant, timely professional learning courses, including webinars, eLearning courses and OnDemand offerings, and keep your professional credits up to date. All for just $399.

Learn more about the subscription!

SUBSCRIBE NOW

DESCRIPTION

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, presented by Peter Connors, provides advisors with the latest techniques and opportunities, and potential pitfalls. 

During this recorded 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
• Calculate the interest expense under Reg. §1. 882-5
• Appropriately apply tax treaty provisions when analyzing branch profits taxes
• Determine withholding tax issues
• Become conversant with the available elections under the branch profits tax

SPEAKERS

PETER J. CONNORS, AMERICAN TAX COUNSEL

Peter J. Connors, J.D., C.P.A., LL.M. practices law in New York, NY.  Each year he publishes numerous Bloomberg BNA Tax & Accounting articles.  Mr. Connors is a fellow of the American Tax Counsel, a member of the Executive Committee of the Tax Section of the New York State Bar, Chair of the New York Chapter of the International Fiscal Association and a former Vice-Chair, Committee Operations of the ABA Tax Section.  He is an author of two Bloomberg BNA Tax & Accounting books, The Branch Related Taxes and the Mark to Market Rules of Section 475 and is a senior partner at Orrick, Herrington & Sutcliffe, LLP