U.S. corporate tax – Fundamentals
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General objectiveCanadian entrepreneurs have increasingly expanded their businesses into the United States, which necessitates the requirement to provide advice on taxation matters that may affect Canadian enterprises and/or their U.S affiliates. Accordingly, this seminar will provide a general overview of the U.S. corporate taxation system, which includes the U.S. Internal Revenue Code and the way in which this code imposes tax and filing requirements on Canadian and U.S. corporations. Subsequently, the session discusses the way in which the Canada-United States Income Tax Convention or treaty provides protections to Canadian enterprises and relief to Canadian taxpayers
Participants will acquire relevant knowledge about common questions from Canadian entrepreneurs expanding their businesses into the United States. Some of these questions concern basic taxation issues and filing requirements associated with different business structures, the appearance of common U.S. corporate tax filings, IRS requirements associated with cross-border payments, and common U.S. state and local tax issues.
ObjectivesBy the end of this training activity, participants will be able to:
- evaluate basic cross-border structures and identify potential U.S. taxation and filing issues;
- analyze how the Canadian-United States Income Tax Convention potentially provide relief to Canadian taxpayers;
- analyze business procedures to identify basic U.S. state and local tax concerns;
- review and evaluate U.S. corporate returns.
- Overview to the relevant laws, including U.S. Internal Revenue Code; Canada-United States Income Tax Convention; and Canadian Income Tax Act
- Overview of treaty protection, including Article V Permanent Establishment; Article VII Business Profits; and withholding rates modification
- Forms of business in the United States
- Overview of the U.S. Corporate Tax Return, including Form 1120; Form 1120-F; Treaty Based Form 1120-F; filing deadlines; estimated tax requirements; and non-compliant penalties
- Case studies of sample Form 1120 and Treaty-Based Form 1120-F
- Computation of taxable income, including basic revenue sourcing rules; basic revenue recognition procedures; common expenditures and basic depreciation calculations
- Transactions between U.S. subsidiaries and Canadian shareholders
- Limited scope overview of state and local taxation
This seminar will benefit the following groups of attendees:
- Practitioners with limited exposure to U.S. taxation
- Professionals who want to improve their understanding of U.S. corporation taxation issues and filing requirements
- Practitioners who wish to provide basic taxation advice to clients expanding their businesses into the United States
Participants enrolling in this seminar should possess some understanding of Canadian international tax principles, in particular, how Canada taxes Canadian enterprises on the repatriation of American profits. However, this seminar does not target international or U.S. tax specialists who are required to prepare complex U.S. corporate tax returns or provide in-depth advice to clients on U.S./international tax matters.