T536 Taxation Of Trans-Pacific Transactions

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.

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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

Audio Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897 (0:00), and (ii) Tax Treaty Articles 7 (4:03), 8 (57:38), 9 (1:01:00), 10 – 12 (1:05:18), 21 (1:38:47), 13 (1:41:55), and 15 (1:45:35).

10-13

01:40:15

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

Audio Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan/US tax teaty (0:00), and (ii) Tax Treaty Articles 5 (4:56) and 6 (1:40:07).

10-13

01:53:42

Audio Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1-4, and (ii) initial discussion on Article 5

Audio Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1 – 4 (0:00), and (ii) initial discussion on Article 5 (1:45:06).

10-13

01:50:21

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

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" (0:00), and (ii) Value Added Tax (1:13:46).

10-13

01:40:37

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

Audio Session 6: (i) General Anti-Avoidance Rules/Substance vs Form (0:00), and (ii) transfer pricing (1:14:38). For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structuring

10-13

01:58:12

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

Audio Session 5: (i) Local Entity Participation Requirements (0:00), (ii) Tax Effective Locations (13:06) including discussion of the Indo-Foods Case (1:35:23), and (iii) Discussion of ABC Case Study Facts and implications thereof (1:54:19).

10-13

02:08:58

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

Audio Session 4: (i) Forms of Doing Business in Another Country (0:00), (ii) Consolidated vs Separate Entity Taxation (1:03:47), (iii) Governmental Incentives including Tax Sparing (1:24:29), and (iv) Discussion of Khoo Holdings Case (1:54:50).

10-13

02:08:16

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

Audio Session 3: (i) Jurisdiction Case (0:00), (ii) Residency and Basis of Taxation (19:25), (iii) Classes of Income and Source (52:11), (iv) Elimination of Double Taxation (1:29:33), (v) Khoo Holdings Case (2:10:57), and (vi) ABC Case (2:13:55).

10-13

02:10:33

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

Audio Session 2: (i) Methodology (0:00), (ii) Ethics and Risks (22:20), (iii) Jurisdiction (42:07), (iv) the Sanctity of the Separate Legal Entity (1:24:34), and (v) Residency and Basis of Taxation (1:42:05).

10-13

02:13:04

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

Audio Session 1: (i) Introductory Comments (0:00), (ii) an In-Class Case Study to demonstrate what "international tax planning" is (25:04), and (iii) Methodology (1:48:02). The Case Study demonstrates what bad can happen if there is no planning.

10-13

02:01:13

Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897, and (ii) Tax Treaty Articles 7–13, 15 and 21

Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897 (0:00), and (ii) Tax Treaty Articles 7 (4:03), 8 (57:38), 9 (1:01:00), 10 – 12 (1:05:18), 21 (1:38:47), 13 (1:41:55), and 15 (1:45:35).

10-13

01:48:18

Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan-US tax teaty, and (ii) Tax Treaty Articles 5 and 6

Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan/US tax teaty (0:00), and (ii) Tax Treaty Articles 5 (4:56) and 6 (1:40:07).

10-13

01:58:51

Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1-4, and (ii) initial discussion on Article 5

Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1 – 4 (0:00), and (ii) initial discussion on Article 5 (1:45:06).

10-13

01:50:21

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

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" (0:00), and (ii) Value Added Tax (1:13:46).

10-13

01:41:28

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

Session 6: (i) General Anti-Avoidance Rules/Substance vs Form (0:00), and (ii) transfer pricing (1:14:38). For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structuring.

10-13

02:03:03

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

Session 5: (i) Local Entity Participation Requirements (0:00), (ii) Tax Effective Locations (13:06) including discussion of the Indo-Foods Case (1:35:23), and (iii) Discussion of ABC Case Study Facts and implications thereof (1:54:19).

10-13

02:17:31

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

Session 4: (i) Forms of Doing Business in Another Country (0:00), (ii) Consolidated vs Separate Entity Taxation (1:03:47), (iii) Governmental Incentives including Tax Sparing (1:24:29), and (iv) Discussion of Khoo Holdings Case (1:54:50).

10-13

02:20:58

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

Session 3: (i) Jurisdiction Case (0:00), (ii) Residency and Basis of Taxation (19:25), (iii) Classes of Income and Source (52:11), (iv) Elimination of Double Taxation (1:29:33), (v) Khoo Holdings Case (2:10:57), and (vi) ABC Case (2:13:55).

10-13

02:19:38

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

Session 2: (i) Methodology (0:00), (ii) Ethics and Risks (22:20), (iii) Jurisdiction (42:07), (iv) the Sanctity of the Separate Legal Entity (1:24:34), and (v) Residency and Basis of Taxation (1:42:05).

10-13

02:23:39

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

Session 1: (i) Introductory Comments (0:00), (ii) an In-Class Case Study to demonstrate what "international tax planning" is (25:04), and (iii) Methodology (1:48:02). The Case Study demonstrates what bad can happen if there is no planning.

10-13

02:04:27

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