This bootcamp is a one-day intensive primer on the fundamentals of documentation, reporting and withholding rules relating to cross-border payments.
Through the use of flowcharts and case studies, this session will illustrate the purpose of the rules and make the rules easier to remember and comprehend. Examples of scenarios that will be covered are:
- An individual opens a bank account to collect payments made to his consulting company. What documentation is required, in the absence of valid documentation, and what withholding regime applies? Could FATCA be involved?
- A foreign vendor provides goods, services, and intangible assets to a U.S. client. How are the various payments to be documented and reported? Could withholding apply to some but not all of the payments? Are expense reimbursements subject to reporting and possibly withholding? What would be the implications if an income tax treaty applied? What forms are used for reporting? Are any returns required by the withholding agent? Does FATCA apply? What happens if the vendor opens a bank account in the U.S.?
- A foreign company makes investments underlying owners. Is FATCA implicated? If so, what is the interaction between FATCA and the nonresident alien withholding rules? If no documentation is provided, what are the presumption rules for determining whether FATCA, NRA reporting and withholding, or domestic withholding and reporting applies?