T536 Taxation Of Trans-Pacific Transactions

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T536 Taxation Of Trans-Pacific Transactions

Creator: Jeffery Kadet

An introduction to practicing taxes internationally with a principal geographical focus on the Asia-Pacific region with particular emphasis on investments into and cross-border transactions with China, Japan, and other countries in the region. The practice of international taxation requires a combin...

EN-US China Education

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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

2011-10-12 23:24:00 1:40:15

T536 Taxation Of Trans-Pacific Transactions

Recent Episodes

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

ECONOMICS OF TAX SPARING

The Indirect Foreign Tax Credit--What It Accomplishes

INTRO CaseStudy Engineering Construction Contract and Analysis

OVERVIEW OF PRAC OF INTL TAX Winter 2013

T536 Course Content

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