ACC 568 ASSIGNMENT WEEK 4

ACC 568 Week 4 Discussion
"The Role of Treaties on International Tax Transactions" Please respond to the following:
Go to the Internal Revenue Service (IRS) Website, located at http://www.irs.gov/Individuals/International-Taxpayers/The-U.S.-Model-Income-Tax-Convention-and-Model-Technical-Explanation. Locate the “U.S. Model Income Tax Convention” used to negotiate treaties with other nations and review Article 5: Permanent Establishment, Article 7: Business Profits, and Article 22: Limitation on Benefits in the model. Next, examine how current U.S. multinational corporations can use provisions of treaties to lower taxes. Speculate how the Internal Revenue Service (IRS) can apply Article 22: Limitation on Benefits to reduce abuse of current treaty provisions. Provide examples to support your response. Imagine you are a CPA representing clients with investments in foreign financial institutions and non-financial foreign entities. Provide your client with at least two (2) ways to avoid penalties under the Foreign Account Tax Compliance Act (FATCA).
Assignment 2: Foreign Taxpayers Engaged in a Trade or Business in the U.S.
Imagine you are an international tax consultant with a foreign client seeking to invest capital in the United States to take advantage of the growing economy. The client is trying to evaluate alternative forms of business to maximize available tax benefits. The foreign client is requesting advice on the best methods to avoid or reduce taxes on income from the investment in a new business with other U.S. investors.
Use the Internet and / or Strayer Learning Resource Center to research the rules related to foreign taxpayers engaged in a trade or business in the U.S. and the related tax effects.
Write a three (3-4) page paper in which you:
Based on your research, identify at least two (2) methods of conducting business in the U.S. for your client, and compare the tax advantages and disadvantages of each that would have the greatest impact on the business. Provide examples to support the advantages and disadvantages identified. Examine at least three (3) categories of U.S. sourced income that will generate U.S. taxes for your client. Provide support for your results. Recommend the most advantageous method of conducting business in the U.S. for your client, and then provide two (2) recommendations for avoiding or reducing taxes on income from the investment. Provide examples to justify your recommendation. Use at least three (3) quality resources in this assignment. Note: Wikipedia and similar Websites do not qualify as quality resources. Format your assignment according to the following formatting requirements: Typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides. Include a cover page containing the title of the assignment, the students name, the professors name, the course title, and the date. The cover page is not included in the required page length. Include a reference page. Citations and references must follow APA format. The reference page is not included in the required page length.
The specific course learning outcomes associated with this assignment are:
Analyze how foreign persons are taxed on income generated in the U.S. Analyze the source rules reach of the U.S. Tax Code in regard to international taxation. Use technology and information resources to research issues in international tax planning and research. Write clearly and concisely about international tax planning and research using proper writing mechanics.