International Cross Border Transactions

• Identify a cross border transaction and be able to discuss potential implications.
• Determine potential audit risks involved with cross border transactions.
• Explain the role of competent authority, advanced pricing agreements and other alternative methods in reducing audit risk.
• Understand the types of contemporaneous documentation needed.
• Apply these principles in order to decrease and entity’s effective tax rate.

• Branch Profits Tax
• Controlled Foreign Corporations
• Transfer of Intangibles
• Effective Tax Rates
• World-wide Taxation
• Territorial Taxation