Principles and Importance of Source of Income Rules for International Tax Planning Reviewed in New BNA Webinar

ARLINGTON, Va., Aug.10 /PRNewswire-USNewswire/ -- Several important concepts in U.S. international income taxation are based on the "source" of items of gross income. A new August 10 webinar from BNA Tax & Accounting, Principles and Importance of Source of Income Rules for International Tax Planning, shows practitioners how to apply the Internal Revenue Code source of income rules to a wide variety of classes of payments in cross-border transactions; determine whether payments made by U.S. persons to nonresident alien individuals and foreign corporations are subject to U.S. withholding tax under the Code; and evaluate the likelihood of whether payments received by U.S. taxpayers in cross-border transactions will support foreign tax credits.

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"Classes of income are sourced under a mixture of statutory, regulatory and 'common law' rules broadly based on the principle that the source of income is the economic activity that gave rise to it," says webinar copresenter John Warner, an attorney with the law firm of Buchanan Ingersoll & Rooney PC.   But specific rules have been developed over time without much internal consistency that cannot always be easily derived from the general principle or that deviate from it in a manner that is not necessarily intuitive. "Understanding these rules thoroughly can help practitioners secure for their clients the most efficient tax treatment available under U.S. federal income tax law and avoid traps with respect to cross-border transactions," adds BNA Tax & Accounting Managing Editor Harold Pskowski.

This 60-90 minute presentation from 12:30 – 2:00 pm ET, focuses on the rules governing the source of income under the Internal Revenue code and U.S. income tax treaties for various classes of income and their significance in international tax planning, particularly with respect to the availability of foreign tax credits for U.S. taxpayers and U.S. taxing jurisdiction over items paid to nonresident alien individuals and foreign corporations.

In 60-90 minutes, participants will gain a rich understanding of Source of Income rules, including

1. Overview of importance of source of income rules
   1. Under the Code and salient regulations
   2. Under U.S. income tax treaties
2. Source of income rules under the Code
   1. Sale of tangible property, including inventory and real property
   2. Sale of stock, including stock of United States real property holding companies
   3. Service fees
   4. Rents
   5. Royalties
   6. Interest
   7. Dividends
   8. Financial guarantees
   9. Income from certain derivatives
   10. Sourcing by analogy
   11. "Source" of deductions
   12. Losses
3. Source as affecting jurisdiction to tax income of nonresident aliens and foreign corporations and withholding tax obligations of U.S. payors
   1. FDAP: only U.S. source income is subject to tax
   2. ECI: generally limited to U.S. source income
4. Foreign tax credit limitation
   1. Foreign tax credit limitation formula in the Code
   2. Possible relief under U.S. income tax treaties

About the Speakers

John P. Warner is a shareholder in Buchanan Ingersoll & Rooney PC practicing in Washington, D.C., where he specializes in international and corporate taxation. He is the immediate past Chair of the Transfer Pricing Committee of the American Bar Association Section of Taxation and is the author of numerous articles and several Tax Management Portfolios. He has litigated several tax cases, including Oak Industries, Inc. v. Commissioner, 96 T.C. 559 (1991), and Libbey v. Commissioner, 55 T.C.M. (CCH) 1052 (1988), and authored an influential amicus brief in Indianapolis Power & Light Co. v. Commissioner, 493 U.S. 203 (1990). He received his BA degree from the George Washington University and a JD degree from the University of California at Berkeley (Boalt Hall) School of Law.

Ansgar A. Simon is tax counsel with Shearman & Sterling LLP in New York, where he has a broad-based tax practice focusing on mergers and acquisitions, corporate restructuring transactions, divestitures (including spin-offs) and joint ventures, with a special emphasis on cross-border transactions, and also regularly advises on tax aspects of capital market transactions and the taxation of financial products. He advised The Dow Chemical Company in the divestiture of its Styron unit to Bain Capital (2010) and in its $19 billion joint venture with a subsidiary of the Kuwait Petroleum Company (2008), and DaimlerChrysler AG in its disposition of 80.1% of Chrysler Holding LLC to Cerberus (2007-2008). He is a member of the executive committee of the tax section of the New York State Bar Association and received a Ph.D. in philosophy from the University of California, Los Angeles and a JD from Stanford Law School.

To register for Principles and Importance of Source of Income Rules for International Tax Planning and obtain further information about CLE and CPE credits, go to http://www.bnatax.com/source-of-income-webinar/ or call 1-800-372-1033, menu Option 6, then Option 1. The fee is $249 for BNA subscribers, $299 for nonsubscribers. To receive automatic, email notification of upcoming BNA webinars that may be of interest to you, go to: http://www.bna.com/emailsignup.htm

About BNA Tax & Accounting Webinars

BNA Tax & Accounting is the foremost source of tax and accounting research, news, practice tools, and guidance for tax attorneys, CPAs, corporate tax managers, estate planners, and financial accountants.  Designed for today's busy practitioners, our webinars offer the same expertise and relevance that are the hallmark of all BNA Tax & Accounting resources. In just 60-90 minutes, practitioners gain in-depth knowledge on a current tax or accounting topic from experts in that area — and benefit from practical applications that can be put to work immediately. Conference attendees have the opportunity to ask the speakers questions, and may be eligible to earn CLE or CPE credits — all from the convenience of their own office or conference room.

SOURCE BNA Tax & Accounting

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