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CANADA — U.S. CROSS-BORDER TAX ISSUES AND STRATEGIES
A Live Two-Hour Audio Seminar from CCH
Tuesday, March 2, 2010 - 1 PM Eastern; Noon Central; 11 AM Mountain; 10 AM Pacific
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
Invite Colleagues, Customers, Prospects and Business Referral Sources to Join You!
Learn about Critical U.S. - Canadian Cross-Border Tax Issues and Tax-Savings Opportunities
The United States and Canada conduct more trade across their borders than any other pair of countries in the world. As a result, understanding the cross-border tax issues and planning opportunities is critical to avoiding double taxation and minimizing the overall effective tax rate with respect to transactions.
Presented by highly-regarded international tax practitioners, Robert J. Misey, J.D., LL.M., M.B.A. and Michael I. Atlas, CA, CPA, TEP, this practical two-hour telephone seminar on March 2, 2010 provides insight and commentary on the hottest U.S.-Canadian cross-border income tax issues, several of which relate to the final effective dates to the recent Protocol to the U.S.-Canadian Tax Treaty.
Professionals in public practice and in industry will benefit from this presentation and will gain a fundamental understanding of tax issues, consequences and opportunities involved with U.S./Canadian cross-border transactions. The presentation time will include opportunities for you to ask questions directly to Mr. Misey and Mr. Atlas via phone and e-mail.
Program Topics
Misey and Atlas will discuss:
- Reduced withholding rates on interest under the Treaty and obtaining refunds
- Canadian tax implications of U.S. LLCs under the new rules, for both U.S. and Canadian residents
- U.S. ownership of Canadian ULCs under the Protocol and potential planning techniques
- Strategic implications of reductions in Canadian corporate tax rates, which will implicate transfer pricing issues
- Dual residency issues
- New Permanent Establishment rules under the Protocol
- Limitations on Benefits rules under the Protocol
- Canadian Revenue Agency's draft forms that are similar to W-8BENs in the United States
Who Should Attend?
- Corporate tax and finance executives, directors, managers and staff; CPAs; CAs; Enrolled Agents; accountants, attorneys and business and financial advisors who work with and advise businesses that have U.S./Canadian cross-border operations and issues
Learning Objectives
- Gain practical understanding of essential U.S. — Canadian cross-border tax issues
- Understand significant new tax developments impacting U.S. - Canadian cross-border transactions
- Identify tax planning issues and opportunities to avoid double taxation and minimize the overall effective tax rate
SPECIAL BONUS
Register today for this insightful program on Tuesday, March 2 at 1 PM Eastern, Noon Central; 11 AM Mountain; 10 AM Pacific.
About the Speakers:
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ROBERT J. MISEY, JR., J.D., LL.M., M.B.A.
Rob Misey is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. and co-chair of the firm’s International Department. He concentrates his practice in the areas of international taxation, transfer pricing and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment.
For U.S. based multinationals, Rob helps clients maximize foreign tax credits and avoid U.S. taxation of foreign earnings to reduce the client’s overall effective tax rate. For foreign owned clients, he coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. Rob’s significant transfer pricing experience allows him to assist multinational businesses with preparing documentation and negotiating Advance Pricing Agreements (APAs). He assists both U.S. and foreign investors in minimizing withholding taxes by taking advantage of applicable tax treaties and offshore corporations and trusts.
Rob's previous experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in its Washington, D.C. national office, where he was a member of the APA team, and a trial attorney and international tax specialist in San Jose, California and the Southeast Region. He also managed the International Tax Services group for a region of a Big Five accounting firm.
Rob regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs across the U.S., Puerto Rico, the U.S. Virgin Islands, Austria, Finland, the Czech Republic and Canada. He has published numerous articles and is a co-author to the treatise, U.S. Taxation of International Transactions, published by CCH. Rob also teaches international taxation at the Master of Tax program in the University of Wisconsin system.
Rob received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer. A native of Milwaukee, Mr. Misey is licensed to practice in Wisconsin, California and the District of Columbia. His professional affiliations include membership in the Tax Section of the District of Columbia Bar Association. He is also a former Chair of the International Practice Section of the Wisconsin State Bar. |
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MICHAEL I. ATLAS, CA, CPA, TEP
Michael Atlas is a Chartered Accountant who practices in Toronto as an independent tax consultant, in connection with a wide-range of domestic and international tax issues. Prior to forming his own practice in 1991, he was the partner in charge of the tax group of one of the 20 largest accounting firms in Canada. His consulting practice places particular emphasis on international and cross-border tax planning matters.
Michael is a frequent speaker on tax matters for many professional and business organizations, including the Canadian Tax Foundation, the Society of Trust and Estate Practitioners, the Institute of Chartered Accountants of Ontario, the Canadian Bar Association, and the Canadian Real Estate Association.
He is an accomplished author and long standing contributor to CCH. He is the author of Canadian Taxation of Non-Residents (3rd Ed.), co-author of “Canadian Taxation of Real Estate (4th Ed.)”, and co-editor of the “Estate Planning in the Twenty-First Century” series, all published by CCH Canadian. Michael has also written many articles that have appeared in CCH's “Tax Topics.”
Michael is a graduate of the University of Texas at Austin and a member of the Institute of Chartered Accountants of Ontario. In addition, he is a U.S. Certified Public Accountant (Illinois). |
How the Audio Seminar Works
CCH’s live audio seminars require nothing more than a telephone connection. For the single per-site fee, you can have an unlimited number of listeners at your site participate, get up to speed and in-the-know on important topics, and get special bonus publications included with the seminar. Handout materials are provided in PDF format that you can download and copy for all those who will participate in the seminar at your location.
Practice Development Tip! Invite colleagues, business referral sources, clients and prospects to your office to listen in and participate on this seminar with you. They’ll appreciate your invitation to hear directly about this important topic.
Visit CCHGroup.com/AudioSeminars for more audio seminar topics, dates and times!
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Earn CPE Credit
- Two hours of CPE credit. One free CPE certificate for one person is provided with each site registration. CPE certificates are available for $25 each for each additional person wishing to receive CPE credit for their participation.
- Course Level: Intermediate
- NASBA Field of Study: Taxes
- Prerequisites: Basic knowledge of taxation of cross-border transactions
- Learn More About CCH’s NASBA Registration
Special Bonus
Firms registering for this audio seminar will receive as a bonus the following publication:
Order CD Recordings of CCH Audio Seminars
If you are unable to attend this upcoming event and would like to order a recording—or if you would like to order recordings of past CCH Audio Seminars, please visit the CCH Audio Seminar Archive Library today.
Pricing:
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Site License: $249 — Registration includes one telephone connection at one location, one master set of handouts (with permission to make additional copies for the participants at your location), an unlimited number of people in one listening room can participate, and one seminar bonus publication per registered site. Each Site License registration includes one free CPE certificate for one person at your site. Additional CPE certificates are available for $25 each for each additional person wishing to receive CPE credit for their participation.
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CD Recording: $249 — The CD includes an audio recording of the event and handout materials in PDF format. Includes copy of seminar bonus publication with purchase. Available one week after the live audio seminar event. (Note: CPE credit is not available for the CD version of the presentation.)
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Site License and CD Recording Package: $349 — This specially-priced package provides you with the Site License access to the live audio seminar event AND the CD Recording.
Our Guarantee
If for any reason you are not completely satisfied with this program, we will provide a full refund - no questions asked!
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
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