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CANADA — U.S. TAX TREATY:
Practical Considerations under the New Protocol
A Live Two-Hour Audio Seminar from CCH
Tuesday, November 10, 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 Practical Issues and Considerations with the Fifth Protocol to the U.S — Canada Tax Treaty
The United States conducts more trade with Canada than any other pair of countries in the world. As a result, understanding the tax treaty between the United States and Canada is critical to avoiding double taxation and minimizing the overall effective tax rate with respect to transactions. The Fifth Protocol to the U.S.-Canadian treaty is now effective. Taxpayers and their advisors need to understand the many significant changes to the tax treaty and how individuals and businesses on both sides of the border can benefit, as well as some potentially adverse changes.
This practical two-hour audio seminar on Tuesday, November 10th, presented by former IRS attorney and noted international tax advisor, author and presenter, Robert J. Misey, Jr., J.D., LL.M., M.B.A., and his colleague, Amy E. Arndt, J.D., will help you understand the now in effect changes and their impact. Professionals in public practice and in industry will benefit from this presentation and will gain a practical understanding of changes from the treaty Protocol that affect cross-border activities of businesses and individuals. The presentation time will include opportunities for you to ask questions directly to Mr. Misey and Ms. Arndt via phone or e-mail.
Program Topics
After attending this seminar, you will understand the following aspects of the Protocol:
- Reductions on withholding taxes and the opportunities for refunds;
- Good news for U.S. owners of LLCs with Canadian activities;
- Bad news for U.S. owners of ULCs in Canada;
- The new provisions providing for taxation as a permanent establishment for cross-border services;
- The approach towards attributing profits to a permanent establishment for taxation;
- Arbitration to eliminate double taxation, and more!
Learning Objectives
- Develop a solid understanding of the changes now effective with the Fifth Protocol to the U.S.-Canada Tax Treaty
- Identify new planning issues and opportunities resulting from this ratification
SPECIAL BONUS
Register today for this insightful program on Tuesday, November 10 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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AMY E. ARNDT, J.D.
Amy E. Arndt is an attorney with the law firm of Reinhart Boerner Van Deuren s.c. in the firm’s Business Law and Tax Practice Areas. Amy’s business background in accounting and economics helps her to understand the goals and challenges facing business clients and to place legal work in an entrepreneurial context. Her practice includes the areas of crisis management and business continuity; entity formation and organization; executive compensation; and mergers and acquisitions.
Amy is a member of the State Bar of Wisconsin, the American Bar Association, and the Milwaukee Bar Association. She received her law degree, cum laude, from the University of Wisconsin-Madison Law School where she was a symposium editor and managing editor of the Wisconsin Law Review. She earned her undergraduate degree from Marquette University’s School of Business with a major in Accounting, also winning the Deloitte & Touche Award for academic excellence. In addition, Amy broadened her business perspective while studying for a year at the European School of Economics in Lucca, Italy, and she later obtained significant business experience in her role as Finance Manager at Coello and Associates, Inc. |
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: Update
- NASBA Field of Study: Taxes
- Prerequisites: None
- 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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