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U.S. Tax Treaties: What You Need To Know

July 29, 2020 1:00 PM EST | 02:40 PM EST

Training Duration = 90 min              Sponsored by Lorman

Click Here to register $219.00

Click Here to register and receive downloadable recording $288.00

Gain a basic understanding on United States tax treaties and how they are enacted.

Income tax treaties play an integral role in international business transactions, impacting taxpayers whose activities cross borders into the jurisdiction of one of the U.S.’s many treaty partners. In the uncertain international business environment we currently find ourselves in, it’s more important than ever for companies to understand the benefits of income tax treaties and how they affect and benefit cross-border planning. This topic will provide you a background of the fundamental aspects of income tax treaties: including why treaties are so important, how they are enacted, and how they impact existing domestic legislation. The major treaty provisions of the U.S. Model Treaty will be reviewed so that you will understand how treaties apply to various business activities and cross-border transactions.


Learning Objectives

  • You will be able to explain the process by which a treaty is entered into force.
  • You will be able to identify the primary provisions of a U.S. income tax treaty.
  • You will be able to describe the application of a treaty to a variety of factual circumstances.
  • You will be able to recognize the benefits of U.S. tax treaties to international commerce.


General Purpose of Treaties
Legal Basis of Treaties
U.S. Treaty-Making Process
Interpretation of U.S. Treaties
Discussion of Treaty Provisions
  • Eligibility for Treaty Benefits
  • Residency Rules
  • Permanent Establishment
  • Business Profits
  • Dividends, Interest and Royalties
  • Limitation on Benefits
  • Administrative Provisions
  • Other Provisions
Treaty-Based Return Positions
U.S. Treaty Network

Matt Anzalone

Crowe LLP

  • Serves as a senior staff with Crowe LLP’s international tax group
  • More than 6 years of experience in international tax including both compliance and planning for public and private companies
  • Has a broad range of industry experience, including manufacturing and distribution, retail and technology, among others
  • Throughout his career he has acquired extensive experience in international compliance issues including completion and review of all U.S. international tax forms
  • Since 2013, he has focused on providing international tax services to publicly and privately held multinational companies on a wide range of international tax issues, including, in addition to the above, structure planning, mergers and acquisition, cross-border transactions, Subpart F and GILTI analysis
  • Prior to joining Crowe, he spent 5 years working at both private and public multinational companies where he gained an extensive background optimizing their tax positions and internal compliance processes as well as their annual transfer pricing reporting and documentation
  • Has specific experience in analyzing tax compliance reporting requirements and developing international cash repatriation projects
  • M.S. degree in taxation, Northern Illinois University