This session will provide an overview of the U.S. taxation of foreign persons, both generally and as it relates to different types of income from active investments. After completing this session, participants will be able to:
- Use the two-part U.S. trade or business (“USTB”) test to determine when a foreign person is subject to U.S. tax on business income
- Determine when income is considered to be effectively connected (“ECI”) to a USTB
- List the differences between the U.S. rules and the BEPS 2.0 Pillar Two minimum tax requirements
- Calculate base erosion and anti-abuse tax (“BEAT”)
Event Details
Wednesday, July 19, 2023
PLI New York
1177 Avenue of the Americas, New York, New York 10036
Speakers
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