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DJH international tax has created a series of courses based on the relevant syllabus for various papers making up the Advanced Diploma in International Taxation.

We began in 2011 with transfer pricing, the ADIT syllabus for which was developed by the course tutors; principles of international taxation was added in 2012; and courses for both US options in 2013. There is now a course available for each option paper.

But you don’t have to be studying for ADIT to benefit from the courses. Many participants, who come from all over the world and from commerce and industry as well as professional practice, say they are new to the topic, want to refresh their knowledge, or have identified gaps they need to fill to work more effectively.

All courses run at a dedicated and fully equipped training venue in central London, convenient for both UK and international travellers. We can also offer help with finding convenient accommodation.

Classes are limited in size to ensure all participants can engage fully and get maximum benefit from the course. All courses run for three and a half days. For transfer pricing the final half day is optional and will be devoted to consideration of sample exam questions.

Courses include: Principles of International Taxation; Principles and Practice of Transfer Pricing; Principles of US International Taxation, and; In-Depth US International Taxation. For more information about the course programs, dates, and pricing, please see our 2014 course brochure.

Information for the Principles of US International Taxation course is provided below.

The Principles of US International Taxation
Course Tutor: Narelle MacKenzie, CPA
Date: December 2-5, 2013

The structure of the US tax system
– Federal taxation vs. state and local taxation
– The federal tax system: the Internal Revenue Code

US federal income taxation: overview
– Basic rule: taxation of worldwide income of US persons
– Individuals
– Corporations
– Partnerships
– Trusts and estates
– Classification of business entities: the “check the box” regime
– Basic rules regarding taxation of non-US persons
– Source of income: section 861 et seq.

Inbound investment
– Non-US person engaged in the conduct of a US trade or business
– Non-US persons not engaged in the conduct of a US trade or business
– Foreign Investment in Real Property Tax Act
– Special US tax treaty issues: Limitation of benefit articles, saving clauses, treaty overrides
– Specific anti-avoidance rules: interest-stripping and anti-conduit regulations

Outbound investment
– Foreign tax credit
– Anti-deferral rules
– Outbound transfers: Code section 367

Other issues
– Transfer pricing rules: Code section 482 and regulations
– Anti-avoidance: general case law doctrines and main statutory provisions
– Estate and Gift Tax
– Indirect Taxes: customs duties; state and local sales taxes

Preparation: No detailed prior knowledge of US taxation is assumed but you will be expected to be broadly familiar with international tax terms.

Am getting excited about speaking next week to CalCPA on international tax – “Peeling the Apple”! SD Taxation: International Tax/Peeling the “Apple” | K2160713 Event Start time: 12:00 pm End time: 2:00 pm Location: San Diego Area Instructor(s): Narelle Elizabeth MacKenzie, CPA Facility: Handlery Hotel & Resort Get Directions group registration Single Registration dP CPE Credits: 2.00 CPE: Continuing Professional Education Technical Do you know how Apple and other multinational corporations navigate through Subpart F and manage to lower their global tax rate well below the US federal statutory rate of 35%? Are you familiar with the interplay between US tax rules and the tax rules of other countries utilized in global tax planning? Don’t miss the opportunity to hear a detailed presentation from Narelle MacKenzie, CPA, international tax consultant, and SDSU lecturer. Objectives: . Gain insight into the operation of Subpart F including exceptions . Discover how other countries might be able to tax local activities . Explore the available planning opportunities due to the interplay of tax rules of the US and other countries Major Subjects: Subpart F of the US IRS code Tax planning structures Worldwide taxation system vs territorial tax system Level of Difficulty: Update Field of Interest: Taxes Prerequisites: None Designed For: CPAs, corporate tax directors, and other professionals who are interested in the process by which a company achieves a low global effective tax rate. Advanced Prep: None Event Notes: The meeting is held at the Handlery Hotel & Resort located just off of IH8 and east of IH5 in Mission Valley. The fee includes lunch, CPE credit, and parking.

Very excited as start the 2013 summer session of Seminar Acctg 659 at SDSU, starting Monday, July 8, 2013!

This is part of the syllabus for the course…

The global economy is an economic reality and taxes are a key component of the global economy as they are paid by taxpayers and fund governments. The United States of America (“US”) has the highest federal corporate tax rate of any OECD country. The highest US corporate income tax rate is 35% and the highest US federal individual tax rate is 39.6%. When you factor in state income taxes, the corporate and individual tax rates are even higher than these amounts if the US person is subject to state income taxes. Taxpayers have a moral and ethical obligation to pay the appropriate amount of taxes – no more, no less.

As students learned in Accounting 321 and Accounting 503, taxation is complex and that understanding the US tax rules is critical to informed decision-making for US taxpayers. This course is the comprehensive study of the federal US tax rules as they apply in an international tax context. Topics include: taxation of US persons; taxation of non-US persons; source of income; FDAP income and withholding; inbound taxation; outbound taxation; foreign tax credits; the role of tax treaties; US anti-deferral regimes and transfer pricing.

Course Objectives: The primary objective is to help you understand the US International Tax rules. You will gain an in-depth understanding of the fundamentals of the US tax law in an international context and apply that understanding with international tax planning concepts. The focus of this course is the US federal income tax rules as it relates to international and cross-border transactions.

You will also use and develop higher-level skills such as the ability to analyze, synthesize and critically evaluate information and rules and then to communicate that critical learning to others in an informative, constructive and ethical manner. ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ ++