International Taxation Update, including the Latest in Transfer Pricing & Customs Issues

Overview: 

Since the introduction of the BEPS Action Plan by the OECD, and the enactment of the Tax Cuts & Jobs Act in 2017, cross-border tax planning has entered a new phase where old plans are rendered ineffective. In addition, most of the world’s tax administrations have changed their transfer pricing legislation as well. This insightful course will give you a comprehensive update on:

  • New developments in international taxation, including their effect on foreign-source income, dividends, and sales or transfers of stock
  • Changes in tax laws of various foreign jurisdictions and the impact of recent cases
  • Transfer pricing legislation worldwide and the practical implementations
  • Current Customs rules and issues and duty reductions/elimination programs, including the First Sale Rule and Trump tariffs
Objective: 

To provide accountants and tax professionals with an in-depth examination of legislation changes in international taxation impacting cross-border tax planning, transfer pricing and Customs issues and laws.

Emphasis: 

International Taxation Update

  • Taxation of foreign source income: prior law vs. new tax law
  • Code §245A and deducting foreign-source dividends received (including hybrid transactions)
  • Treatment of sales or transfers of stock in foreign corporations (Code §1248)
  • Expansion of Subpart F: new FDII ownership rules
  • Global Intangible Low-Tax Income (GILTI)
  • Code §250 FDII deduction and the Foreign Derived Intangible Income deduction
  • Code §962 election and subsequent distributions
  • Changes in tax laws of various foreign jurisdictions with an emphasis on Europe after BEPS and ATAD II
  • European attacks on state aid
  • DAC 6 and ATAD II adopted by the European Commission
  • The Danish cases in the European Court of Justice

Transfer Pricing Update

  •  BEPS as a catalyst for the Tax Cuts & Jobs Act after Altera and Amazon
  • Impact of disclosure through Country-by-Country reporting and documentation
  • The creation of “value creation”
  • New OECD intangible asset definition in action, “hard to value” intangibles
  • New services pricing guidance
  • Strategies for managing US and “Rest-of-OECD” transfer pricing policies and controversy
  • The groundwork for updated financial transactions rules and “BEPS 2.0”

Customs Issues & Laws

  • Customs Informed Compliance and Reasonable Care
  • Customs entry requirements and procedures
  • Customs rulings and legal opinions
  • Customs classification
  • Bases of Customs Valuation (Appraisement)
  • First Sale Rule
  • Countervailing and antidumping duties
  • Duty reduction programs: NAFTA, other free trade area agreements, drawback
  • Trump tariffs: steel, aluminum, and automobile tariffs, and Section 301 tariffs against China: how to cope, what to do, how to file exemptions
  • Duty elimination programs
Bottom
Prerequisite: 

Basic knowledge of federal taxation and some level of international taxation.

Preparation: 

No advance preparation required.

Level of Knowledge: 

Basic.

CPE Credit: 
8.00
NASBA Field of Study: 
Taxes