The International Taxation Course which will be focused on major elements of the US Taxation Law.
The US Tax Law Course will be aimed and focused on the sector of already experienced lawyers, accountants and other professionals with interest in Finance and Tax Law and who have proved experience and knowledge in the field of Taxation and are interested in learning about major elements of the US Tax Law.
As it is ISDE’s Philosophy we do not only mean our students to reach the most up to date knowledge about US Tax Law, but to acquire the skills that will help them to reach their professional goals.
To do so we count on an academic staff composed by the most important lecturers related to the Tax Law in the US. Their commitment in making of this Program the best Executive Course in US Tax Law is the guarantee of its quality.
The main importance of the Program is focused on teaching topics on major elements of US Tax Law, which the professional daily life of an international lawyer, Tax or Finance Manager and other professionals are not too much elaborated on.
• An overview introduction to GAAP.
Introduction to the basics of US corporate tax system
Decide the best alternative to invest: subsidiary versus branch.
• The taxation of C corporations and their shareholders.
• The taxation of a branch.
• Case study
• The use of partnerships in business transactions with an emphasis on the sale rules, anti-mixing bowl rules, partnership mergers and divisions, and partnership incorporations.
• Case study: How these rules affect transactions in practice, including Private Equity Funds, Hedge Funds and Real Estate Joint Ventures.
US liquidation and reorganizations tax implications
• The liquidation of corporate subsidiaries and Section 338 elections.
• The transfers to controlled corporations Section 351.
• The taxation of acquisitive corporate reorganizations.
• The taxation of divisive reorganizations and corporate spinoffs.
• Case study: Practical application of regulations. Issues derived from reorganizations: cancellation of indebtedness; use and limitations on tax attribute carryovers.
• The US Model Income Tax Convention and the treaty jurisprudence of the US. Relationship between tax treaties and domestic law, treaty interpretation, entitlement to treaty benefits, the concepts of "resident" and "permanent establishment," taxation of income from business and services and of dividends, interest, and royalties, relief of double taxation, non discrimination, and exchange of information.
• Special focus on the Tax Treaty signed between US and Spain, and the changes introduced due to the signature of the new Tax Treaty.
Spanish multinational carrying out a business in the US
• Inbound US taxation:
• Tax efficient acquisition structure:
• Project financing
• Case study
Outbound US taxation
• The taxation of US taxpayers investing abroad
• Case study
• The anti- deferral provisions
• Case study
• Transfer pricing rules- general overview.
• Transfer pricing considerations in Business restructuring, systems implications.
• Tax effective supply chain management (TESCM).
• Taxation of income from derivatives: options, futures, forwards, swaps, and other instruments.
• Tax treatment of debt instruments. coupon "stripping" and market discount bonds, preferred stock, including "hybrid" securities, contingent capital, convertible bonds, and contingent convertible bonds.
• Debt versus equity instruments. The basic federal income tax rules applicable to that classification.
• How the investment banking community develops financial instruments.
• Securitization structures.
Leasing and asset finance
• Asset leasing and financing transactions, cross- border structuring and taxation advice.
Taxation of Private equity Funds &Transactions
• Tax considerations that arise in structuring private equity funds and their transactions, analyzed at the investor level, the fund level and the “target” company level.
Taxation of Banks
• General Classifications of Banks.
• Taxation of Banks. Special provisions.
• Interaction of taxation and regulation.
• Deferred tax assets (“DTA”) in bank regulatory capital.
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