Treaties and Other International Agreements: Basic Overview

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This course presents an overview of tax treaties and how they are used in structuring transactions and determining the tax impact of cross-border transactions.  It discusses the ordering rules for local laws versus treaty laws, and the purpose of the tax treaties in avoiding and eliminating double taxation to promote trade and investment. The participant will learn about planning opportunities to contemplate when structuring foreign operations.

Basic Course Information

Learning Objectives

• Acquire a better understanding of the international tax environment.
• Describe the purpose of income tax treaties in the tax regimes of countries.
• Recognize qualifications for a permanent establishment.
• Be able to discuss common treaty provisions in the US Model Treaty.
• Understand typical reduced withholding rates on dividends, interest and royalties.
• Describe the rules by which a taxpayer must disclose a tax position to the IRS for claimed treaty benefits that is in conflict with the IRC.
• Ascertain mutual agreement procedures between the taxing authorities of two treaty countries in cases of double taxation.
• Recognize when a company/citizen would need to file Form W8-BEN with the IRS in order to claim treaty benefits for US tax withholding.          

Major Subjects

• What is a Treaty?
• Basis of Taxation
• Permanent Establishment
• Relationship between treaties and domestic law
• Model Treaties
• Competent Authority Agreements

Professor Allison McLeod is currently a full-time Senior Lecturer at the University of North Texas, and has taught classes in Corporate Income Taxes, Multi-jurisdictional Taxation, Individual Taxes, Tax Research, Ethics and Financial Accounting. Prior to going into academia, she worked for 18 years in industry and in a Big Four accounting firm.

Professor McLeod earned a law degree from Baylor School of Law, and an LL.M. degree in Taxation from Southern Methodist School of Law.

She has been a licensed CPA since 1993 and has been licensed to practice law since 1992.  She is a member of the Professional Ethics Committee for the Texas Society of CPAs and works part time for the Dallas law firm of Grable Martin Fulton, PLLC.

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