Inbound Business Activity in the U.S.
U.S. tax rules for inbound business activity, clarifying the applicable law for foreign individuals and entities with business or financial ties to the United States.
Format
Online
NASBA Field of Study
Taxes
Level
Basic
CPE Credits
1
Author(s)
Chaya Siegfried
Availability
1 year
Product Number
USITIBA26SSO
Navigating U.S. tax rules for foreign taxpayers
Foreign individuals and entities conducting business in, or receiving income from, the United States face a layered set of withholding, filing, and income tax rules. This course explains how U.S.-sourced fixed, determinable, annual, or periodical (FDAP) income and effectively connected income (ECI) are identified, sourced, taxed, and reported.
Withholding and reporting responsibilities
Learners explore the several reporting responsibilities, including the following:
- The role of withholding agents
- The documentation needed to support payee status
- The use of Forms W-8 and W-9 The course also addresses common exceptions to FDAP withholding, including treaty-based reductions and the portfolio interest exception, while distinguishing those rules from Foreign Account Tax Compliance Act (FATCA) documentation requirements.
Business activity and treaty analysis
The course also compares the U.S. trade or business standard with the permanent establishment standard that applies under many tax treaties.
Through examples, learners examine how facts and circumstances affect whether foreign corporations have U.S. taxable income, whether protective returns should be filed, and how the branch profits tax can apply to U.S. branch operations.
Note: This course is an except from International Taxation, part of Tax Staff Essentials Level 4.
Who Will Benefit
- Tax practitioners advising foreign individuals or entities with U.S. income
- CPAs working with inbound international tax issues
- Professionals responsible for withholding, documentation, or reporting for payments to foreign persons
- Learners seeking foundational knowledge of U.S. taxation of foreign persons
Key Topics
- FDAP income and withholding
- ECI
- Forms W-8, W-9, 1042, 1042-S, 1120-F, and 8833
- FATCA documentation rules
- Tax treaty exceptions and limitation on benefits provisions
- U.S. trade or business standard
- Permanent establishment standard
- Branch profits tax
Learning Outcomes
- Identify the U.S. taxation of fixed, determinable, annual, or periodical (FDAP) income of foreign persons.
- Identify the U.S. taxation of effectively connected income (ECI) of foreign persons.
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