Introduction to United States Income TAX Treaties

Dictated by:

Professor Dalton L. Dallazem

International Tax Professor and Advisor

Science Juris Doctor – SJD (UFPR – Brazil)

SJD Candidate – International Taxation – (UF – United States)

  • Start Date: 08/24/2020 - 13:00 UTC Time
  • End Date: 08/28/2020 - 15:00 UTC Time
  • Language: English
  • Price: 80 US Dollars
  • Total Course Time: 6 Hours
  • Includes a Digital Certificate from WORLDWIDE TAXNET LTD

Bellow you have the payment methods for subscribing this course.

If you want to pay with debit or credit card, select the black button. Then, choose your country, complete the form and press the payment button. In case you have a Paypal Account, you can pay with the Paypal button.

In order to confirm your attendance, please send us an email to contact@worldwidetaxnet.com once the payment is done.

If you have a discount, write it below and press "Process Coupon"

*The next day of your payment, you should receive an email from us. Do not forget to check the spam section.

Full Program:

Session I

  • Overview of U.S. Tax Treaties – Structure and Sources of Income
  • Income Tax Treaties versus Internal Revenue Code – Treaty Override
  • Residence: - Citizenship - Substantial Presence and Tie-Breaker Rules - Saving Clause
  • Fixed, Determinable, Annual or Periodic Income – FDAP (Dividends, Interests and Royalties)

Session II

  • Business Income
  • Trade or Business and Permanent Establishment
  • Personal Services Income

Session III

  • Anti-treaty Shopping Provisions (Limitation on Benefits – LOB)
  • Relief from Double Taxation
  • 2017 Tax Reform and Dividends Received Deduction (DRD)

Recommended reading (not mandatory)

  • Avi-Yonah, Reuven S., International Tax as International Law (March 2004). U of Michigan Law, Public Law Research Paper No. 41; Michigan Law and Economics Research Paper No. 04-007. Available at SSRN: https://ssrn.com/abstract=516382 or http://dx.doi.org/10.2139/ssrn.516382
  • Kysar, Rebecca M., Unraveling the Tax Treaty (July 15, 2019). Minnesota Law Review, Forthcoming. Available at SSRN: https://ssrn.com/abstract=3420398
  • https://www.irs.gov/individuals/international-taxpayers/tax-treaties
  • https://www.irs.gov/businesses/international-businesses/united-states-model-tax-treaty-documents
  • Filippo Alessandro Cimino – Associate Professor of Tax Law, Kore University of Enna (Italy)

For any doubts or issues, please write us to contact@worldwidetaxnet.com