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Course Details

I Need to Do What? Taxation of International Payments in a FATCA-Filled World

Webinar: ID# 1016959
Recorded CD
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I Need to Do What? Taxation of International Payments in a FATCA-Filled World
About This Course:
In today's global economy, business transactions take on a cross-border nature at an ever-increasing clip. They may include ordinary activities like purchasing materials from a Chinese supplier, paying a German consultant, or receiving a payment from a Brazilian customer, as well as more complex variants.

Too often these transactions - even those in the ordinary course of business - lead U.S. companies into a maze of cross-border tax reporting and withholding regulations, and into the many traps for the unwary.

This topic offers an introduction to filing and withholding obligations covering outbound and inbound payments or transactions. It also includes a special focus on the Foreign Account Tax Compliance Act (FATCA); an Act that took effect in July 2014 and is generating widespread angst in the cross-border community.

This webcast will guide you in avoiding profit-killing pitfalls, quickly recognizing common red flags, and increase your ability to take proactive steps to eliminate burdensome penalties and traps for noncompliance.

Agenda

Inbound Payment Taxation
  • Direct Payments From Non-U.S. Sources
  • Payments Received by a Foreign Subsidiary
  • Payments Received From a Foreign Subsidiary
Outbound Payment Taxation
  • Introduction to Income Tax Withholding on Payments to Nonresident Aliens and Non-U.S. Entities
  • Foreign Person Defined
  • Buying U.S. Real Estate From Foreign Persons
  • Dividends, Interest, and Other Passive Income Payments
  • Foreign Partner Withholding
  • FATCA Introduction
  • Brief Overview of Background and Intent
  • Discussion of Key Definitions, Including Foreign Financial Institution (FFI) and NonFinancial Foreign Entity (NFFE)
  • Description of FATCA Implementation, Timing and Mechanics
  • Discussion of Identification, Withholding and Reporting Rules
  • Outbound Payment Examples:
  • Purchasing Real Estate From a Foreign Person
  • Paying a Dividend to a Foreign Shareholder
  • Paying Interest or Principal to a Foreign Lender
  • Buying Goods From a Foreign Vendor/Supplier
  • Paying Salaries to Foreign Workers
  • Investing in a Foreign Entity
About The Presenters

Joshua A. Ehrenfeld
  • Counsel with Burr & Forman LLP, Nashville office
  • Practices in the firm’s corporate and tax group, and focuses on domestic and international taxation, cross-border M&A and finance transactions
  • Represents businesses and entrepreneurs in financing transactions, including fund formation, private placement transactions, equity and debt offerings
  • Represents multi-national companies and individuals on global personnel and expatriate tax issues
  • Represents clients on Export Control matters, including ITAR and EAR compliance issues
  • LL.M. degree in taxation, University of Florida Levin College of Law; J.D. degree University of Chicago Law School; B.A. degree, College of William and Mary
J. Allen Sullivan, Jr.
  • Partner with Burr & Forman LLP, Birmingham office
  • Practices in the firm’s corporate and tax group, and focuses on tax planning and tax controversy
  • Regularly represents taxpayers before the IRS in challenging international and domestic tax assessments and penalties in audits, at IRS Appeals, and in the IRS’s Offshore Voluntary Disclosure Initiatives
  • Regularly represents clients in Foreign Corrupt Practices Act (FCPA) matters as well as Export Controls (e.g., ITAR and EAR) and other international compliance matters
  • LL.M. degree in taxation, University of Florida Levin College of Law; J.D. degree Cumberland School of Law at Samford University; B.A. degree, Auburn University
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I Need to Do What? Taxation of International Payments in a FATCA-Filled World
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