T536 Taxation Of Trans-Pacific Transactions

By Jeffery Kadet

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Description

An introduction to practicing taxes internationally with a principal geographical focus on the Asia-Pacific region with particular emphasis on investments into and cross-border transactions with China, Japan, and other countries in the region. The practice of international taxation requires a combination of both knowledge and mental processes. Knowledge includes international tax principles and mechanisms and how various countries implement them. Mental processes include the approaches and skills required to analyze a cross-border business or investment, identify the relevant issues, arrive at alternative approaches that resolve the issues, and help the decision-maker reach conclusions. This course focuses on international income taxation concepts, principles and planning as applied generally in countries around the world and specifically within the Asia-Pacific region. There is also a section on value added tax as well as considerable discussion of tax treaties. The course is not focused on the US. As such, only a little time is spent on US tax rules and then mostly for illustration and comparison purposes. The video version of the course has been edited to include slides and other materials to help the viewer. As the audio version does not include these materials, the video version should be used if at all possible. A course paper written by the instructor (required reading for attending students) and several course handouts discussed in class are provided in pdf format. There's also pdf file that includes the content of each of the ten course sessions.

Episode Date
T536 Course Content
Oct 13, 2011
OVERVIEW OF PRAC OF INTL TAX Winter 2013
Oct 13, 2011
INTRO CaseStudy Engineering Construction Contract and Analysis
Oct 13, 2011
The Indirect Foreign Tax Credit--What It Accomplishes
Oct 13, 2011
ECONOMICS OF TAX SPARING
Oct 13, 2011
Session 1: (i) Introductory Comments, (ii) an In-Class Case Study to demonstrate what "international tax planning" is, and (iii) Methodology. The Case Study demonstrates what bad can happen if there is no planning
2:04:07
Oct 13, 2011
Session 2: (i) Methodology, (ii) Ethics and Risks, (iii) Jurisdiction, (iv) the Sanctity of the Separate Legal Entity, and (v) Residency and Basis of Taxation
2:23:39
Oct 13, 2011
Session 3: (i) Jurisdiction Case, (ii) Residency and Basis of Taxation, (iii) Classes of Income and Source, (iv) Elimination of Double Taxation, (v) Khoo Holdings Case, and (vi) ABC Case
2:19:38
Oct 13, 2011
Session 4: (i) Forms of Doing Business in Another Country, (ii) Consolidated vs Separate Entity Taxation, (iii) Governmental Incentives including Tax Sparing, and (iv) Discussion of Khoo Holdings Case
2:20:58
Oct 13, 2011
Session 5: (i) Local Entity Participation Requirements, (ii) Tax Effective Locations including discussion of the Indo-Foods Case, and (iii) Discussion of ABC Case Study Facts and implications thereof
2:17:31
Oct 13, 2011
Session 6: (i) General Anti-Avoidance Rules/Substance vs Form, and (ii) transfer pricing. For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structuring
2:03:03
Oct 13, 2011
Session 7: (i) ABC Case Facts and implications including discussion of approaches to transferring intangibles and tangibles across border as well as some implications of using "check-the-box entities", and (ii) Value Added Tax
1:41:28
Oct 13, 2011
Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1-4, and (ii) initial discussion on Article 5
1:50:21
Oct 13, 2011
Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan-US tax teaty, and (ii) Tax Treaty Articles 5 and 6
1:58:51
Oct 13, 2011
Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897, and (ii) Tax Treaty Articles 7–13, 15 and 21
1:48:18
Oct 13, 2011
Audio Session 1: (i) Introductory Comments, (ii) an In-Class Case Study to demonstrate what "international tax planning" is, and (iii) Methodology. The Case Study demonstrates what bad can happen if there is no planning
2:01:13
Oct 13, 2011
Audio Session 2: (i) Methodology, (ii) Ethics and Risks, (iii) Jurisdiction, (iv) the Sanctity of the Separate Legal Entity, and (v) Residency and Basis of Taxation
2:13:04
Oct 13, 2011
Audio Session 3: (i) Jurisdiction Case, (ii) Residency and Basis of Taxation, (iii) Classes of Income and Source, (iv) Elimination of Double Taxation, (v) Khoo Holdings Case, and (vi) ABC Case
2:10:33
Oct 13, 2011
Audio Session 4: (i) Forms of Doing Business in Another Country, (ii) Consolidated vs Separate Entity Taxation, (iii) Governmental Incentives including Tax Sparing, and (iv) Discussion of Khoo Holdings Case
2:08:16
Oct 13, 2011
Audio Session 5: (i) Local Entity Participation Requirements, (ii) Tax Effective Locations including discussion of the Indo-Foods Case, and (iii) Discussion of ABC Case Study Facts and implications thereof
2:08:58
Oct 13, 2011
Audio Session 6: (i) General Anti-Avoidance Rules/Substance vs Form, and (ii) transfer pricing. For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structuring
1:58:12
Oct 13, 2011
Audio Session 7: (i) ABC Case Facts and implications including discussion of approaches to transferring intangibles and tangibles across border as well as some implications of using "check-the-box entities", and (ii) Value Added Tax
1:40:37
Oct 13, 2011
Audio Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1-4, and (ii) initial discussion on Article 5
1:50:21
Oct 13, 2011
Audio Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan-US tax teaty, and (ii) Tax Treaty Articles 5 and 6
1:53:42
Oct 13, 2011
Audio Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897, and (ii) Tax Treaty Articles 7–13, 15 and 21
1:40:15
Oct 13, 2011