T536 Taxation Of Trans-Pacific Transactions

Audio Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897, and (ii) Tax Treaty Articles 7–13, 15 and 21

Audio Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan-US tax teaty, and (ii) Tax Treaty Articles 5 and 6

Audio Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1-4, and (ii) initial discussion on Article 5

Audio Session 7: (i) ABC Case Facts and implications including discussion of approaches to transferring intangibles and tangibles across border as well as some implications of using "check-the-box entities", and (ii) Value Added Tax

Audio Session 6: (i) General Anti-Avoidance Rules/Substance vs Form, and (ii) transfer pricing. For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structuring

Audio Session 5: (i) Local Entity Participation Requirements, (ii) Tax Effective Locations including discussion of the Indo-Foods Case, and (iii) Discussion of ABC Case Study Facts and implications thereof

Audio Session 4: (i) Forms of Doing Business in Another Country, (ii) Consolidated vs Separate Entity Taxation, (iii) Governmental Incentives including Tax Sparing, and (iv) Discussion of Khoo Holdings Case

Audio Session 3: (i) Jurisdiction Case, (ii) Residency and Basis of Taxation, (iii) Classes of Income and Source, (iv) Elimination of Double Taxation, (v) Khoo Holdings Case, and (vi) ABC Case

Audio Session 2: (i) Methodology, (ii) Ethics and Risks, (iii) Jurisdiction, (iv) the Sanctity of the Separate Legal Entity, and (v) Residency and Basis of Taxation

Audio Session 1: (i) Introductory Comments, (ii) an In-Class Case Study to demonstrate what "international tax planning" is, and (iii) Methodology. The Case Study demonstrates what bad can happen if there is no planning

Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897, and (ii) Tax Treaty Articles 7–13, 15 and 21

Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan-US tax teaty, and (ii) Tax Treaty Articles 5 and 6

Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1-4, and (ii) initial discussion on Article 5

Session 7: (i) ABC Case Facts and implications including discussion of approaches to transferring intangibles and tangibles across border as well as some implications of using "check-the-box entities", and (ii) Value Added Tax

Session 6: (i) General Anti-Avoidance Rules/Substance vs Form, and (ii) transfer pricing. For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structuring

Session 5: (i) Local Entity Participation Requirements, (ii) Tax Effective Locations including discussion of the Indo-Foods Case, and (iii) Discussion of ABC Case Study Facts and implications thereof

Session 4: (i) Forms of Doing Business in Another Country, (ii) Consolidated vs Separate Entity Taxation, (iii) Governmental Incentives including Tax Sparing, and (iv) Discussion of Khoo Holdings Case

Session 3: (i) Jurisdiction Case, (ii) Residency and Basis of Taxation, (iii) Classes of Income and Source, (iv) Elimination of Double Taxation, (v) Khoo Holdings Case, and (vi) ABC Case

Session 2: (i) Methodology, (ii) Ethics and Risks, (iii) Jurisdiction, (iv) the Sanctity of the Separate Legal Entity, and (v) Residency and Basis of Taxation

Session 1: (i) Introductory Comments, (ii) an In-Class Case Study to demonstrate what "international tax planning" is, and (iii) Methodology. The Case Study demonstrates what bad can happen if there is no planning