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PERMANENT ESTABLISHMENTS:
Understanding PE Concepts, Trends and Consequences
A Live Two-Hour Audio Seminar from CCH
Tuesday, November 3, 2009 - 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 the Key Concepts, Trends and Consequences Surrounding Permanent Establishments
One of the most challenging international tax issues is the expanding definition of “permanent establishment” (PE) in today’s global business and investment environment. A central provision of all income tax treaties, a PE determines the threshold of taxation of business profits of enterprises at source in foreign countries. Developed in a “bricks and mortar” world, the traditional PE rules are no longer clear-cut and there are numerous traps for the unwary. At the same time, taxing authorities worldwide are looking for opportunities to increase revenues, interpreting the PE concept using factors such as a business’s server location and different transfer pricing regimes to create nexus and levy taxes. PE and profit attribution issues are red-hot right now, so it is absolutely vital that businesses and practitioners involved with cross-border activities thoroughly understand PE concepts and consequences.
This two-hour audio seminar presentation with noted international tax experts, Carolyn Turnbull, CPA, M.S.T. and Joseph E. Sardella, CA, CPA, will provide you and your staff with not only with the necessary background and a solid understanding on permanent establishments, but also an up-to-date discussion of new developments, trends, concerns and strategies. Beginning with an overview of the fundamental rules and consequences of permanent establishments, the seminar will move into the current questions, issues, tips and best practices regarding PEs. With PE-based examinations on the rise, you don’t want to miss this important discussion on key PE rules, interpretations and application to help facilitate cross-border compliance and administration. Time will be provided for you to ask question via e-mail or over the phone to Ms. Turnbull and Mr. Sardella during the program.
Program Topics
Turnbull and Sardella will discuss and explain an array of permanent establishment concepts and considerations, including:
- Consequences of PE status — why is this discussion so important?
- Key factors and considerations for determining PE status
- Permanent establishments under the revised model OECD income tax treaty
- The interplay and relationship between PE and transfer pricing
- The “asset-use” test and “business-activities” test in determining income attributable to a PE
- Inclusions and exclusions to the PE “fixed place of business” and “business activitites” standards
- Distinguishing between dependent and independent agents
- Attribution and allocation of income and expenses between PE and home office
- Treatment of interest, debt, capital structures, R&D, overhead and administrative expenses
- Treatment of profits on intangible assets and apportionment of such assets and income
- Significant PE-related cases
- PE for unique situations, such as electronic commerce, partnership interests, construction projects, etc.
- PE definition for “services” under the 5th Protocol to the Canada-U.S. tax treaty
- Requirements to be able to file a U.S. PE treaty-based return
- Use of protective income tax returns under Reg. Sec. 1.882-4
- Gray areas and practical strategies to avoid PE status
- Treaties of U.S. with countries that have Limitations on Benefits (LOB) clauses
- PE audit trends and triggers
Learning Objectives
- Understand the fundamental concepts surrounding permanent establishment and the consequences of PE status
- Gain awareness of special situations and areas that can potentially trigger permanent establishment status
- Identify potential opportunities to minimize PE assertion and increased tax liability with proper planning
Who Should Attend?
Corporate tax and accounting staff responsible for cross-border tax compliance and planning; public practice CPAs, EAs, tax attorneys and other business and financial advisors working with business clients on international tax compliance and planning matters
SPECIAL BONUS
Register today for this insightful program on Tuesday, November 3 at 1 PM Eastern, Noon Central; 11 AM Mountain; 10 AM Pacific.
About the Speakers:
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Carolyn Turnbull, CPA, M.S.T.
Carolyn is the Director of Tax for Moore Stephens Tiller, LLC in Atlanta. She has more than 28 years of experience assisting companies across a wide range of industries and their owners to minimize their tax liability and maximize their profitability. Carolyn has extensive experience dealing with complex partnership and corporate tax issues at the federal, state and international levels. She is a member of the IRS Advisory Council and she has been recognized as one of the Top 50 IRS Representation Practitioners in CPA Magazine. Carolyn is very active with the AICPA, where she currently serves on the AICPA Tax Executive Committee and as a technical reviewer and presenter for various AICPA continuing professional education programs. She has participated on the AICPA’s cross border merger and acquisitions, Form 5472, Form 5471, Form 1042, Form 1120F, and Form 8858 international tax task forces. Carolyn is a frequent speaker at tax seminars and in webcasts on a variety of corporate, partnership, and international tax topics. |
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Joseph E. Sardella, CA, CPA
Joseph Sardella is an International Tax Partner for MSCM LLP in Toronto. He advises both personal and corporate clients that are expanding into the U.S. and international tax markets. Joseph has more than 17 years of practical experience in U.S. and Canadian personal and corporate tax from senior level positions held in public corporations and international accounting firms. He has extensive experience in taxation matters relating to U.S. corporate and expatriate tax compliance; U.S. and cross border structuring and financing; hybrid entities, tax controversy, tax treaty interpretation, U.S. reorganization and state nexus issues. Joseph is a member of the Ontario and British Columbia Institutes of Chartered Accountants, as well as the American Institute of Certified Public Accountants. He is a licensed CPA in Illinois and is a member of the New York, Florida, California and Missouri Society of CPAs. Joseph is also an IRS certifying acceptance agent and an active member of the AICPA Tax Focus groups which work with the IRS in developing U.S. tax legislation. He has written for or been quoted in numerous articles in professional publications and the press. |
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 are available for an additional $25 per person wishing to receive a CPE certificate for their participation
- Course Level: Intermediate
- NASBA Field of Study: Taxes
- Prerequisites: Basic knowledge of U.S. international taxation principles
- 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. ($25 CPE fee additional for each person wishing to receive a CPE certificate 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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