2) Performing a transfer pricing analysis for a particular multinational group, and assisting the group in implementation. Additionally, he has worked with some of the biggest Indian corporate houses for tax advisory work in connection with their corporate group structures, outbound acquisitions, family settlements, succession planning and regular tax advise. The course will also examine issues such as tax expenditures,debt vs. equity,cost recovery, andvarioustax incentives. in National and Global Health Law, J.D./LL.M. kpmg international tax reform analyzer (itra) is an excel-based tool that allows for extensive modeling of international tax rulesincluding those introduced by tcja and the cares act, prior existing provisions, and biden administration and congressional tax planswith support from experienced international tax professionals to help tailor Watch: Sanjana Rao LLM '22 on how the program expanded her range as a lawyer. 2022 Copyright owned by one or more of the KPMG International entities. Our dynamic program develops curious and thoughtful tax leaders who become prepared for future careers in the field. Note: Required for foreign-trained Tax LL.M. September 2021 Looking for international taxation course by kpmg? Note: FIRST CLASS ATTENDANCE IS MANDATORY. Cancel anytime from the account management page. Case Study 12 - Interest paid by a Foreign Bank Branch to overseas HO and other Branch - Non Resident Taxation. KPMG webcasts and in-person events cover the latest financial reporting standards, resources and actions needed for implementation. Penalty charges for Late Payment - Not Interest, Article 11 (4) - Interest and PE in Source State, Article 11 (5) When Shall Interest Arise in a Contracting State, Case Study - 4 - Interest Borne by PE in other Contracting State, Case Study - 5 - Interest Borne by PE in Third Contracting State, Article 11 (6) - Excess Interest Payment to Related Party, Case Study - 6 - Excess Interest Payment to Related Party, Special relationship for disallowance of Excess Interest Payment to Related Party, Computation of Excess Interest Payment to Related Party, Key Learning Points to be learnt about taxation of Royalties, Which Country has the Right to Tax Royalty Income ? International tax treaties determine why hedge funds are located where they are, how motion pictures are financed, whether the dispatch of employees abroad is economical, and why financial assets follow prescribed international paths. During the first half of the course, the instructors will focus on international transfer pricing and related topics. There will be an overview of treaty provisions that apply to investment income and income from the performance of services. liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a . IFRS 17 Challenges - Audit, Accounting, Regulatory and Tax Aspects - In practice, Transfer Pricing Deep Dive Series: Transfer Pricing Compliance in Malta, Transfer Pricing Deep Dive Series: Intangibles and Cost Contribution Agreements, Transfer Pricing Deep Dive Series: Business Restructuring, Updates: Income Tax and Duty Highlights for the Year 2022. Sovereign Wealth funds - Residence and Exemption from Tax. LAW743v00 Transfer Pricing: Selected Topics. The course incorporates concepts learned in all of the tax courses as they relate to the impact on cross-border outbound transactions (i.e., the taxation of US taxpayers doing business abroad). This course is designed for students with little or no background in tax treaties. Day 2-Model Tax Conventions on Double Tax Avoidance. Case Study 11 - Adjustment and Scope of Assessment - Advance Pricing Agreement. International Tax, KPMG US +1 973-912-6590. By the end of the course, students are expected to understand how tax treaties are organized and be able to apply the model tax treaties to factual situations in which the tax treaties are applicable. LAW710v00 Advanced International Taxation, LL.M Course (cross-listed) | 2 credit hours. This course assumes that students have some familiarity with basic tax treaty concepts and examines how provisions of the OECD Model Treaty and the United States Model Treaty are used by tax practitioners to achieve specific business objectives. Mergers & Acquisitions Tax. Taxation of Charitable Trusts Are they "Liable to tax" ? Waitlisted students must be in attendance at the start of the first class session in order to remain eligible to be admitted off the waitlist. Online courses specific to ADIT Altium Training If issues are not decided under MAP ? 4) Apportioning group-wide expenses. KPMG Tax Business School Brochure View the KPMG Tax Business School Brochure (PDF 900KB) Download pdf (1.2 MB) . . Course Features Guided Learning 62 hours Language English Assessments CBE Share: Description Schedule Trainers 395.00 You May Like At the same time, the course is intended to challenge the student to be aware of the ethical challenges and risks of practice in the area of international taxation. Nationality - When does it decide residence ? The course will cover a broad range of topics with particular emphasis on the tax consequences of cross-border reorganizations, liquidations and taxable acquisitions and dispositions. Credits: 12. This is not simply a question of capital mobility, but of longer, more specialized and more international supply chains. KPMG in India's International Tax and Regulatory Services team comprises dedicated tax professionals with in-depth technical knowledge and practical experience, who the client can trust in relation to corporate tax and regulatory matters. This will include infrastructure, wealth tax,cross-border tax, consumption taxesand other politically salient tax policy topics. Get the latest KPMG thought leadership directly to your individual personalised dashboard, Advanced certification program on IFRS along with NIIT Imperia, IFRS 15 and IFRS 16 e-learning programmes, KPMG's course for accounting professional, RBI mandate on capacity building in banks, Blockchain masterclass: Unblocking the blocks, IIRC approved training course on Integrated Reporting, Lean Six Sigma Green Belt Certification Training Program, LeanSix Sigma Black Belt Certification Training Program, Lean Six Sigma Master Black Belt Certification TrainingProgramme, Overview and Insight into SCRUM methodology training, Official Introduction to CMMI-DEV Ver. Course (cross-listed) | 3 credit hours. Specific goals of the course are to assist foreign students in gaining a general perspective on the United States system and to provide domestic students and practitioners a sufficient level of understanding of the area and practices to provide a platform for the development of further interest in the area. Is your employer paying for your CPE seminars? Taxation of International Transactions. LL.M Course (cross-listed) | 1 credit hour. 1.3 High Maturity Practices Workshop, -DEV based IQA Workshop (CMMI-DEV, ISO9001), -SVC based IQA Workshop (CMMI-SVC v1.3, ISO20000), -Q-Champ Assessment Certification Programme, -Project management professional (PMP) certification training, - The Future Learning and Development Leader programme, -Certified instructional design practitioner's course, -Design Thinking Practitioners Workshop, KPMG in Indias GRI Certified Training Course on Sustainability Reporting, KPMG Course for Learning and Development Professionals. A new era in international tax | 3 4 Internationalization of business The fourth stream is the increasing internationalization of business. It will cover fundamental tax treaty concepts such as residency, permanent establishment, business profits, limitation on benefits, and relief from double taxation (including operation of the U.S. foreign tax credit rules). Ruth is a warranted lawyer and graduated with a Doctor of Laws from the University of Malta in 2016. In addition, students will learn about the interaction of tax treaties with U.S. domestic tax law, the role of international organizations in interpreting tax treaties, procedures for resolving tax treaty disputes through the competent authority process, and strategies for researching tax treaties. Georgetown offers a Certificate program in the increasingly important field of international taxation. International Taxation Course - CA Arinjay Jain - Recorded International Tax Course is available on scheduled manner. KPMG International provides no client services. Kpmg LLP International Tax Partner. The KPMG Tax Internship Experience is designed to help provide you a multi-disciplinary introduction to business and tax topics. 1.3 and High Maturity practices in Agile Environment, -Multimodal Internal Quality Auditor Workshop, -CMMI-DEV Ver. The International Taxation Committee helps members to build their working knowledge on the provisions of International Taxation laws and to acquire an analytical approach to apply this working knowledge to specific problem areas in a variety of practical situations. My ACC 530 (Advanced Income Taxation) course had an outstanding current topics in #taxation panel this year featuring Connor Quillen (KPMG), Mark Vande Guchte LinkedIn Nathan Goldman#taxation #inflationreductionact #globalminimumtax #tcja Ruth also regularly delivers classes in various courses relating to international tax. Article 13(1) - Capital Gains Arising from Aliennation of Immovable Property, Meaning of Alienation of property for Capital Gains, Article 13(2) OECD Model Convention - Movable Property of PE Business, Article 13(2) - Capital Gains on Sale Movable Property of PE, "Tax on Gains from Sale of Capital Asset after cessation of PE ", Case Study Transfer of Movable and Immovable Property, Article 13(3) - Capital Gains fom Sale of Ships or Aircrafts operated in International Traffic, Article 13(4) - Capital Gains Arising From Alienation of Shares of Real Estate Company, Case Study 1 - Value from Immovable Property, Case Study 2 - Less than 50% value from IP, Case Study 3- Value from IP - Comprehensive, Article 13(5) - Alienation of any Other Property, Assets Whose Transfer Could Be Covered Under Residuary Clause, Factors Not Considered To Be Relevant While Applying Article 13(5), Salaries, Wages & Other Similar Remuneration - Meaning, Article 15 (3) Remuneration of Crews of Ships or Aircraft, Meaning of directors fees and other similar payments, Overview of Article 17 - Entertainers and Sportspersons, Article - 17(1) Right of Source State to Tax income. In these podcasts, KPMG professionals discuss U.S. international tax and OECD-related tax guidance and provide concise, practical insights about the impact on multinational enterprises. Those supply chains increasingly separate intellectual property, marketing capacity and support services into jurisdictions which are . The Certificate in International Taxation can also be completed entirely online. Specific lecture topics will include 1) Overview of the international transfer pricing system. Georgetown Law's online programs, which include the Executive LLM in Taxation, Executive LLM in Securities & Financial Regulation, MSL in Taxation, and Certificates in International Tax and State and Local Tax, will not lead to professional licensure and will not qualify a student to sit for any state bar exam. Studentswill write short papers withrespectto the regulatory packages we examine, and write a final paper reflecting on the strengths and weaknesses (or lack thereof) of the new international tax regime, or particular statutory and regulatory provisions therein of students choosing. 5) Enforcement issues. Failure to attend the first class session in its entirety will result in a drop; failure to attend any subsequent class session in its entirety may result in a withdrawal. Enrolled students must be in attendance at the start of the first class session in order to remain enrolled. For enrollment / inquiry contact us at in-fmkpmgacademy@kpmg.com. This course is intended to teach the concepts underlying the United States Model Tax Treaty and the OECD Model Tax Treaty. Kurt Farrugia, Associate Director, International Tax Advisory, KPMG in Malta Kurt is an Associate Director at KPMG forming part of the firm's international tax team. Note: ATTENDANCE IS MANDATORY AT ALL CLASS SESSIONS. 2002. In addition, we will consider the major international tax policy documents published by the OECD and the relationship between the negotiations at the OECD and U.S. international tax policy developments. Note: Enrolled students will have until the beginning of the second class session to request a drop by contacting the Office of the Registrar; a student who no longer wishes to remain enrolled after the second class session begins will not be permitted to drop the class but may request a withdrawal from an academic advisor in the Office of Academic Affairs. Michail Tegos, Associate Director, International Tax Advisory, KPMG in Malta. Contact us onkla@kpmg.com.mtto discuss how the employer can benefit from our offers. U.S. International Tax Course offers an unmatched faculty of tax educators specializing in U.S. international tax matters. Click here for programme details and schedule. Case Study 13 - NRI returning to India . She read her Advanced Masters in International Taxation at the International Tax Centre, University of Leiden in the Netherlands and graduated cum laude in 2018. Habitual abode - When does it decided residence ? The goal of the course is to provide an overview of the relevant law and policy considerations, with a focus on specific issues that are presently contested as a policy matter. Concentrates on the U.S. taxation of foreign persons and foreign investments in the United States. Transfer pricing involves the division of taxable income resulting from cross border transactions including the sale of goods and services and the licensing of intangibles. in International Arbitration and Dispute Resolution from Tsinghua Law School in Beijing, Masters in International Affairs from Sciences Po in Paris, Masters of Public Health from Johns Hopkins, International Arbitration & Dispute Resolution, https://compliance.georgetown.edu/student-consumer-information/distance-education, Search LL.M International Taxation Certificate Courses. Permanent home - What constitutes Permanent Home to determine residence ? Article 4(1) of OECD Model Who is Resident ? Federal Tax Course - Level 2 focuses on more advanced federal tax matters and is designed for tax professionals with 5+ years of experience. No member firm has any authority to obligate or bind KPMG International or any other member firm vis--vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. Students get the skills necessary to prepare taxes for individuals and corporations with foreign activities, or for foreigners with US activities. Kurt is an Associate Director at KPMG forming part of the firm's international tax team. In addition to transfer pricing, students may choose paper topics from other international tax topics with a practical application including permanent establishments, tax treaties, international arbitration, and the competent authority process. Meanwhile, at the multilateral level, the Organisation for Economic Cooperation and Development (OECD) has proposed major changes to the mechanisms for coordinating different countries assertion of tax jurisdiction over income earned cross-border, in order to shift some taxing rights to market countries and impose a globally agreed minimum tax on corporate income. Prerequisite: Federal Income Taxation (formerly Taxation I) and prior or concurrent enrollment in one course in international taxation. Purpose: The aim of this module is to provide students studying towards an accounting degree with a well-rounded and systematic knowledge . Instruction explores the application of U.S. tax law to U.S. individuals and entities conducting transactions outside the U.S., as well as foreign . In depth coating information regarding international taxation course by kpmg Free coating guidance Canada Recommended: Prior or concurrent enrollment inFederal Tax Practice & Procedure or any International Tax Course. Ruth is a warranted lawyer and graduated with a Doctor of Laws from the University of Malta in 2016. The course covers the U.S. taxation of passive and business income of nonresident aliens and foreign corporations, the source rules, the principles and application of U.S. tax treaties, special rules governing foreign investment in U.S. real estate and other business, cross border financing transactions, the base erosion and anti-abuse tax, and tax planning possibilities involved in the foregoing. Our global network of international tax professionals work to . The objective of the exercise will also vary from week to week --for example, a pre-filing conference memo aimed at persuading the IRS National Office international rulings personnel to respond favorably if a request is filed on a cross-border spinoff; the executive summary of a Competent Authority request to resolve a withholding tax interpretative issue under an applicable treaty; strategic analysis and recommendations regarding the most tax effective approach to bring products to the EU or APAC market, to finance an international acquisition or to tax-effect losses incurred in a particular country operations. All rights reserved. KPMG can support you in . What EY can do for you. International Tax Interpretation of Tax Treaties (DTAA) Careers Alumni . Centre of vital interest - Importance in Determination of Residence. Article 11(3) - What is regarded as Interest ? Recommended: Prior or concurrent enrollment in a course in international taxation. with Certificate in Legal English for Foreign-Trained Lawyers, J.D./LL.M. J.D. Article 13 Capital Gains - Key Aspects and Meaning of Capital Assets ? Compliance considerations and withholding tax requirements are key areas of focus. This programme provides participants with a broad overview of international taxation and how this has impact on cross-border activities, arrangements and transactions that involve the movement of persons, capital, goods and services across borders. 3) Current developments including the taxation of services, intangibles, and OECD guidance. What is included within the meaning of Dividend ? The course begins with an introduction to the U.S. compliance regime, including the obligation to report worldwide income, specified foreign financial assets and international business activity. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. The ECJ itself cannot harmonize the tax systems, however, the Court can force the member states to open their tax systems for tax competition within Europe. Day 1-An overview of International Taxation and Principles of International Tax Law. . The course will examine the economic and policy rationales for such taxes and study in detail how different types of value added taxes work, including tax calculations and cross-border aspects. Students will learn the various international tax reporting obligations, applicable statutes of limitations and tolling provisions, potential civil penalties under the Internal Revenue Code and the Bank Secrecy Act, options for resolving non-compliance, procedures for challenging proposed and assessed penalties, and the risk of criminal investigation and prosecution. The course concludes with study of current international enforcement and litigation trends involving cross-border business transactions and base erosion/profit shifting issues. The course focuses on very recent judgments of the Court of Justice. . 2.0 Overview Training Course, -Data Management Maturity Model Training, -Insight to CMMIVer. + View More. For more detail about our structure please visit https: . The course examines, in depth, U.S. taxation of the international operations of U.S. multinational corporations. Member firms of the KPMG network of independent firms are affiliated with KPMG International. 1.3 and High Maturity practices in Agile Environment, Multimodal Internal Quality Auditor Workshop, CMMI-DEV Ver. Prerequisite: Federal Income Taxation (formerly Taxation I). 1-3 Months IE Business School Globalization, Economic Growth and Stability Find your ideal online course for the Principles of International Taxation module here. The judgments delivered by the ECJ are most of the time very surprising, even to experts. Students will acquire an understanding of how treaty provisions help shape economic and financial decisions in different industries and economic sectors. Keeping tax positions up to date. Important Note: Graduate certificate admission is limited to domestic students. Phone: (202) 662-4056 Program Course Requirements: 1) U.S. Inbound International Taxation; 2) U.S. Outbound International Taxation; 3) Tax Treaties; 4) Survey of Transfer Pricing (available online) or Transfer Pricing: Selected Topics; 5) One additional course in international taxation (a minimum of 2 credits). Each firm will be asked each week to undertake a new project for the senior partner/client relating to the facts and requests for advice/assistance set forth in the case study. Useful class participation will be taken into account as a plus in determining the final grade. . This session is aimed at equipping the attendees with a brief overview of the identified fields within the international tax arena in order to enable them to identify issues that may require further detailed analysis, and prepare them for the novel measures being proposed at an international level. All rights reserved. This course seeks to provide an introduction to the United States' principals and current practice of international transfer pricing, as well as some understanding of the historical and conceptual basis of the current system. There will be no final exam. She read her Advanced Masters in International Taxation at the International Tax Centre, University of Leiden in the Netherlands and graduated cum laude in 2018. By the end of the course, students are expected to be able to understand where the borders of ethical behavior are when developing international tax structures and to be able to analyze risks to the clients and themselves when working in this area. Transfer pricing typically leads to the largest audit disputes between multinational corporations and the national tax administrations for the countries in which these companies do business. These courses have been updated with the most recent international tax guidance, including regulations and notices addressing changes to rules for Foreign Tax Credit (FTC), Global Intangible Low-Taxed Income (GILTI) and Base Erosion and Anti-Abuse Tax (BEAT). Following graduation from his masters degree, he was handpicked and asked to stay on as the academic coordinator for the next two-and-a-half years, and he still lectures on the taxation of shipping and air transport. It will explore the economic and policy literature surrounding the issues of economic welfare and competitiveness. At the end of the course, students will have a broad technical understanding of indirect taxes and an appreciation of the policy concerns that animate legislative and academic discussion of this important subject. Mutual Agreement - Determination of Residence by Competent Authority, Article 4(3) of OECD Model - Tie breaker other than an Individual. students may take the seminar pass/fail by professor permission only. 1.3 Course, -Official Introduction to P-CMMVer. The U.S. International Tax Certificate program is a comprehensive learning program . This is the third edition of the joint initiative between IBFD and IFA LATAM. While tax treaties ostensibly are only about dividing up tax bases between countries and exchanging information between sovereigns, in reality they channel the flow of investment and development in the global economy. Course Fee: Rs.40,000/- which shall include 120 hour International taxation Professional Training (INTT PT) and Background Material for the Course. Mutually Excluded Courses: Students may not receive credit for both this course and the J.D. 2022 KPMG, a Maltese civil partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. Ruth also regularly delivers classes in various courses relating to international tax. Georgetown is also authorized separately to deliver online education to students residing in California. Home Business Tax Compliance Transformation Employment & Mobility Asset Management & Private Enterprise Tax Indirect Taxes Future of Tax Global Legal Services & KPMG Law Regional Tax Centers Our approach LAW3063v00 International Tax Controversy. Prerequisite: Prior or concurrent enrollment in Corporate Income Taxation I (or the JD course, Corporate Taxation (formerly Taxation II)) and a course in international taxation. I am an expert in International Taxation and M&A tax structuring wherein I have worked with KPMG as a Director in Indian practice helping large number of MNC, as well as domestic companies in the area of Inbound Investments, Outbound acquisition, cross border tax structuring, amalgamation, demerger, business sale amongst others. The course will also consider how the U.S. rules in these areas are influenced by developments in other countries. View all news | View all events. Sorry, this page could not be found. To learn more, please contact: All learning programmes are offered under the auspices of the KPMG Learning Academy. Research topics in international taxation Martin Hearson 7.2k views 9 slides Tax treaties and developing countries Martin Hearson 5.3k views 20 slides Assignment international taxation Eesha Gupta 2.2k views 19 slides BASICS OF INTERNATIONAL TAXATION Shailendra Kumar Mishra 8.4k views 26 slides International Taxation Overview & Update The course uses examples drawn from actual practice to illustrate the creative use of tax treaty provisions. We are not sure what might have caused this error, but our team has been automatically notified and will start looking into it as soon as possible. Recommended: Prior or concurrent enrollment in Corporate Income Tax Law II (or completion of Corporate Taxation). The seminar's final exercise will involve yet another twist in the company's life cycle. To know more about other programmes offered, click here . International Taxation Navigating Tax Obligations and Uncertainties at Home and Abroad Cross-border commerce offers immense growth potential and a significant opportunity for many companies. As an accountant Kurt joined the tax function of KPMG in 2014 after reading for the Master in Accountancy course at the University of Malta (UM). Read more. In 2015 Ruth joined KPMG Malta and is currently a Manager within the International Tax advisory team, being particularly involved in the provision of direct tax Advisory services to international corporate clients. This colloquium will offer students an opportunity to examine current tax policy issues in depth and at an advanced level, with discussions led by policymakers, economists, and other tax experts. Presently, he is running his boutique tax and regulatory advisory firm wherein he is advising several MNC who are looking at setting their India operations/acquisition of companies in India, with key clientele in Solar power sector, IT& ITES, manufacturing, e-commerce etc. NQF level: 7. Since joining KPMG in 2002, Juanita has worked in corporate taxation, providing advice to multinationals seeking assistance in tax matters and related planning. All sessions will be taught by global indirect tax professionals from KPMGs Washington D.C. office. Requirements for U.S.-Trained Students and all Online Students: Requirements for Foreign-Trained Students: Contact Information When can a PE arise in Source State - Office, Site or an Agent ? This course comprises the following modules: 01 module. The session is aimed at accountants, corporate service providers, law firms, sole practictioners and other professionals that are interested in the fast-paced international tax field and that are involved in structures that may be affected by the new rules. students pursuing the Certificate in International Taxation. Enrolled students must be in attendance at the start of the first class session in order to remain enrolled. With the pace of globalization accelerating, U.S. tax professionals increasingly advise foreign clients, for whom indirect taxes may constitute a large percentage of aggregate tax liability. He is an Associate Director at KPMG Malta involved in the provision of tax advice to a broad range of international businesses, including a number of multinationals, in respect of a diverse range of projects including tax structuring, group restructuring and financing, and in the provision of advice on international tax issues as regards investments made into, out of or through Malta. ITIL is a registered trade mark of AXELOS Limited, used under permission of AXELOS Limited. , Article 12 (3) Taxation of Royalties when a Permanent Establishment exists in Source State, Key Questions to understand Application of Article 12(3), Article 12 (4) Excess Payment due to Special Relationship between Payor and Payee. International Tax Partner (Accountant) at Kpmg LLP. Note: Required for U.S. trained students pursuing the Certificate in International Taxation. The grade for this course will be based primarily on papers that students submit addressing policy topics discussed by the guest speakers. Article 25(5) - Can a tax payer invoke "Arbitration". Michail, a lawyer, read his masters in tax law at the International Tax Center, University of Leiden, the Netherlands. 2.0 Overview Training Course, Insight to CMMIVer. He has lectured at the KPMG Business School in the fundamentals and advanced international tax training (in Amsterdam and Hamburg). Georgetown Law is a member of the State Authorization Reciprocity Agreement (SARA), which allows online programs that demonstrate compliance with their home state's authorization requirements to enjoy reciprocal authorization in all other SARA states, which include D.C., Puerto Rico, and all U.S. states except California. Note: WEEK ONE COURSE. We will study these documents and the underlying policy considerations, and discuss the impact on U.S. multinational tax planning. Students Studying for the ACCA qualification through KPMG Learning Academy benefit from a tax credit of 70% of the costs incurred via the Get Qualified Scheme. In 2015 Ruth joined KPMG Malta and is currently a Manager within the International Tax Advisory team, being particularly involved in the provision of direct tax advisory services to international corporate clients. Concentrates on the U.S. taxation of U.S. persons and businesses earning income outside of the United States. Ellis Duncan, Director of the Graduate Tax Program Our international tax professionals provide leading-edge tax consultancy services for many of the world's largest multinational companies. KPMG International entities provide no services to clients. The course will cover the tax consequences of outbound transfers of assets, foreign-to-foreign transfers of assets, and inbound transfers of assets. Prior to setting up his own practice in October 2014, he worked as Director, in the M & A Tax division at KPMG in India. All rights reserved. Semester module. This course is traditionally held in early August. IBFD - IFA LATAM Webinars, News on International Taxation and Its Impact in Latin America. This course is an advanced topics courses. Email Address: Ellis Duncan, Note on State Authorization to offer Online Programs Students will be expected to have a working knowledge of corporate taxation, and transactional aspects of subpart F and the foreign tax credit rules. Passthroughs & Partnerships. This course analyzes the tax treatment, issues, planning techniques and underlying government policies involved in doing business internationally. I have worked with KPMG as a Director in Indian practice helping large number of MNC, as well as domestic companies in the are of Inbound Investments, Outbound acquisition, cross border tax structuring, amalgamation, demerger, business sale amongst others. The course will have a take-home exam that must be completed during the week of January 21 and January 28, 2023. each of which is a separate legal entity. My ACC 530 (Advanced Income Taxation) course had an outstanding current topics in #taxation panel this year featuring Connor Quillen (KPMG), Mark Vande Guchte Nathan Goldman on LinkedIn: #taxation #inflationreductionact #globalminimumtax #tcja Principles of International Taxation online courses 21 Apr 2021 Online courses offer an accessible way of supporting your exam preparation while enhancing your understanding of the subject. Finally, our speakers will delve into the latest updates with respect to the taxation of the digital economy, including the OECD proposals in Pillar I. The course will discuss variouscurrent and recent legislativeproposals at a detailed level and examine the economic, tax policy, and political considerations underlying the decisions that have been made in each proposal. However, students will be expected to have a basic understanding of the U.S. tax rules that apply to foreign persons who receive income from the United States and U.S. persons who receive income from abroad. About this course: This course is for accounting, tax, and finance professionals; international business managers; and lawyers who work with cross-border transactions involving the United States. The class will be divided into separate "law firms"of4 or so students per firm. Prerequisite: Federal Income Taxation (formerly Taxation I) and either prior or concurrent enrollment in Corporate Taxation (formerly Taxation II) or Corporate Income Tax I. The only real engine of harmonization seems to be the European Court of Justice (ECJ). LAW756v01 U.S. International Outbound Tax. 1.3 High Maturity Practices Workshop, DEV based IQA Workshop (CMMI-DEV, ISO9001), SVC based IQA Workshop (CMMI-SVC v1.3, ISO20000), Q-Champ Assessment Certification Programme, Project management professional (PMP) certification training, The Future Learning and Development Leader programme, Certified instructional design practitioner's course, Design Thinking Practitioners Workshop. This course will introduce students to indirect taxation, exemplified by the European Unions Value Added Tax (VAT) and Canadas Goods and Services Tax (GST), two of the fastest-growing indirect taxes globally. Article 5(1) When does a Fixed Place PE arise under DTAA ? The Workshop will use a "case study" approach to address the myriad technical, practical and strategic issues involved in counseling a company as it evolves from astart-up operating out of its founder's garage (in the first week of the semester) to a Fortune 100 global powerhouse with operations on every continent. In the past, he has worked on several clients from US, Germany, Singapore, Netherlands and UK in respect of setting up their Indian operations and acquisitions of various business in India. Japanese Consumption Tax suffered by your business during sports and other major international events held in Japan in 2020 may be unclaimable as a refund. More and more, tax authorities are not only looking to penalize a taxpayer for improper tax planning, but also the tax advisor who recommended the course of action followed by the taxpayer. List of trainings offered by KPMG Learning Academy in India, Accounting Advisory Services (AAS) Learning Solutions, -Advanced certification program on IFRS along with NIIT Imperia, -IFRS 15 and IFRS 16 e-learning programmes, -KPMG's course for accounting professional, -Refresher training course on Indian GAAP, -RBI mandate on capacity building in banks, -Blockchain masterclass: Unblocking the blocks, -IIRC approved training course on Integrated Reporting, -Lean Six Sigma Green Belt Certification Training Program, - LeanSix Sigma Black Belt Certification Training Program, -Lean Six Sigma Master Black Belt Certification TrainingProgramme, -Overview and Insight into SCRUM methodology training, -Official Introduction to CMMI-DEV Ver. course International Tax Law or U.S. On successful completion, participants will receive a certificate from KPMG in India. LAW1633v00 Current Developments in International Taxation Seminar, J.D. LAW058v06 International Tax and Business Planning Workshop, LL.M Seminar (cross-listed) | 3 credit hours. I am an expert in International Taxation , M&A tax , UAE Economic Substance Regulations and Tax structuring . However, this potential for new business opportunities also comes with increased complexity and potential exposure. All rights reserved. Prerequisite: Federal Income Tax and International Tax (or U.S. International Inbound Tax and U.S. International Outbound Tax). Introduction and Basic Concepts of Tax Treaty, What is Tax Treaty and Various Tax Treaty Models, Various Treaty Model - OECD, UN and US Model, Content and General Provision applicable to Tax Treaty, Principle and Approach to Interpret tax treaty, Different views on Taxation of Two contracting States, Article 2 - Taxes - Overview of Article 2 in Tax Treaties, Relevance of Article 2 - New Taxes, Additional taxes and other aspects, Article 2 (1) Taxes covered under Treaties, Article 2 (2) Meaning of Taxes for OECD Model, Article 2 (3) Existing Taxes covered under Treaty, Article 4 - Overview of Concept of "Residence", Importance of Concept of Residence in Tax Treaties. Article 5 (2) Specific Places included in Fixed Place PE, Article 5(3) Building Site, Construction or Installaton Project, Installation PE Activities Resulting in Installation PE, 12 Month Test Aspects , Computation and Anti Abuse Provision, Case Study Fiscally Transparent Partnership, Article 5(4) - Specific Activities Exempted from Constituting a PE, Article 5(4)(a) - Facilities for Storage etc, "Article 5(4)(b) - Maintenance of a stock of goods or merchandise ", Article 5(4)(c) - Maintenance of goods - processing, Article 5(4)(d) - Purchasing Goods/ Merchandise for the Enterprise, Article 5(4)(d) Collecting Information for the Enterprise, Places constituting preparatory work activities, Article 5 (4.1) Office constitutitng Closely related Co PE, Key Characterstics of the dependent agent PE, Article 5 (6)- Independent Agent not constituting a PE, Article 5(7) - Subsidiary Permanent Establishment, Case Study - Holding Subsidiary Relationship, Article 6 - Income From Immovable Property - Key aspect and income covered, Article 6(1) Right Of Source State To Tax Income From Immovable Property, Article 6(2) Meaning Of Immovable Property, Article 6(3) Nature Of Income Covered , Article 6(4) Immovable Property Of Enterprise , Method of Computation Of Income In Source State, Case Studies (1-3) on Article 6 Income From Letting And Subletting, Relevance of Article 7 - Business Profits, Structure of Article 7 - Business Profits, Article 7(1) - Taxing Rights of Contracting State, Article 7(2) - Determination of Profits of a PE. Taxation of Domestic Persons with Activities Outside of the U.S.); or U.S. LAW986v01 U.S. International Inbound Tax. We will also speak with government representatives involved in crafting the regulations and negotiating multilaterally. It strives to provide aspiring practitioners with the desired confidence to . Module presented in English. This is a basic tax treaty course. LAW2038v00 Current Issues in Tax Policy, LL.M Seminar (cross-listed) | 2 credit hours. Japan Consumption tax rate in 2020 If the applicable period for your consumption tax liability is from October 1, 2019 onwards, the following tax rates apply. Reading materials generally will be supplied and will include economic and tax policy papers, legislative proposals, and technical explanations. Finally, the course is intended to reinforce principles of close reading and attention to the specific wording used in the tax treaties and cases interpreting the tax treaties. For more information on state authorization, including state complaint processes and refund policies the university is required to comply with, please visit Georgetown's office of Compliance and Ethics web page:https://compliance.georgetown.edu/student-consumer-information/distance-education, For more information on SARA please visit:https://www.nc-sara.org/. Case Study 10 - Presumptive taxation Transfer Pricing. The course is intended to be highly interactive with students discussing design and policy issues with leading experts in the field. Jim Tod. Cancellation charges i.e. KPMG Executive Education has developed and delivered over 1,000 internal and external programs on trending topics and emerging issues in the accounting and finance industry, taught by KPMG leaders, industry specialists, and highly regarded academics from prestigious universities. The topic of international transfer pricing that is, how a business conducting operations in a number of different countries should divide its taxable income among those countries remains among the most practically important of international tax issues. Students that plan to study on an F or J Visa may apply to graduate programs only. This course will study current developments in US international tax policy through a close reading of selected tax regulatory packages associatedwith the2017 tax reform. As an accountant Kurt joined the tax function of KPMG in 2014 after reading for the Master in Accountancy course at the University of Malta (UM). Module presented online. Our course is one of the limited courses in international taxation available online, that deals with interpretation of tax Treaties, Global Minimum Tax, BEPS and other international tax matters. 2022 KPMG Assurance and Consulting Services LLP, an Indian Limited Liability Partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. This course will provide students an opportunity to explore the international taxation topic of transfer pricing through the research and writing of a graduate paper. Advanced Diploma,Under Graduate Degree. Note: The course will include occasional presentations by guest speakers experienced in the field of international tax. This course concentrates on real world civil and criminal tax controversies involving international tax matters facing todays tax practitioners. Deduction of Expenses - Rules violating Treaty? By the end of the course, students are expected to be able to read and understand why specific words are used in tax treaties and the significance of these words. A basic knowledge of how these taxes work is thus a valuable asset for any lawyer doing corporate or international tax work. The introductory course in transfer pricing is recommended, but not required. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. Article 10(2) - Right of Source State to Tax Dividend, Beneficial ownership of Dividend - Meaning and case study, Third Party Beneficial Owners of Dividend, Beneficial ownership and Test of beneficial ownership, Article 10(4) - Taxation of Dividend Connected to PE or Fixed base, Article 10(5) - Right to tax dividend declared by Foreign Co. From income from Source State, Article 11 - Interest - Overview of Article 11, Learning Aspects of Article 11 - Interest, Article 11 (1) Right of State of Residence to Tax Interest, Case Study - 1 - Interest Taxed on Payment Basis, Case Study 2 Interest From Third State Person, Case Study 3 Interest Attributable to PE in Third State, Deduction of interest based on Residence of Recipient of Interest, Article 11 (2) - Right of Source State to Tax Interest, Case study Third State beneficial owner of interest, Third Party Beneficial Ownership - Examples and Cases, Disadvantage of Gross Taxation Example - Banks, Case Study Gross WHT and impact on International Trade, Interest Exemption - Other Contracting State is Recipient, Interest Exemption - Contracting State is Payor, Interest Exemption - Export Financing Agencies and Programmes, Interest Exemption - Interest paid to financial institutions, Interest Exemption - Credit Sales and interest on Delayed payment. It covers the recently enacted GILTI rules, the Foreign Tax Credit provisions, Subpart F,repatriation,and overall strategic tax planning, including the significant new U.S. international tax rules and other changes introduced by the 2017 Tax Cuts and Jobs Act. Taxation of Individuals - TAX3702. Most legislative measures of the European Union in this area require the consensus of all 27 member states. 1.3 Course, P-CMMVer. Students should leave the course with an understanding of the basic framework for U.S. international tax law and a sense of some of the policy debates surrounding the current rules. The course will address both how individual and corporate foreign taxpayers are taxed by the United States, and how U.S. individual and corporate taxpayers are taxed by the United States on income earned in or from other countries. KPMG's tax practice works with you to learn all we can about your organization, understand your goals, and uncover opportunities. Ruth Bonnici, Senior Manager, International Tax Advisory, KPMG in Malta. INspire HK: Future Ready Talent initiative will develop talent to build Hong Kong's 'eight centers' HONG KONG, CHINA, Dec 7, 2022 - (ACN Newswire) - This year marks the 25th anniversary of Hong Kong's return to the motherland and Deloitte's 50th anniversary in Hong Kong. Pre-requisite: FAC1601 & TAX2601. Taxation of Foreign Persons in the United States); or U.S. International Outbound Tax (formerly: U.S. If you have a question about accessible employment at KPMG, or to begin a confidential conversation about your individual accessibility or accommodation needs through the recruitment process, we encourage you to contact us at cafmcdnhrsthotline@kpmg.ca or phone 416-777-8002 or toll free 1-888-466-4778. Case Study 9 - Income deemed to accrue or arise in India. Four years later, significant changes to that new system are being proposed. Mutually Excluded Courses: Students may not receive credit for both this course and the J.D. The Certificate is open to both U.S. and foreign-trained lawyers, as well as non-attorney taxprofessionals, and can be completed together with the Tax LL.M. For more detail about our structure please visit https://home.kpmg/governance. During this session we will discuss the salient updates from the international tax arena, concentrating both on EU initiatives and beyond. 15+ years. Article 26(1) - Obligation to exchange information on Contracting States', Article 26(2) - Use and secrecy of information obtained under Exchange of Information, Scope of Article 27 - Assistance in Collection of Taxes, Article 27(1)- Contracting States - Obligations To Lend Assistance , Article 27(2)- Meaning of Revenue Claim that can be enforced , Article 27(4) - Measures Of Conservancy , Article 27(5)- Priority Of Revenue Claim , Article 27(6)- Proceeding Before Courts , Article 27(7)- Revenue Claim Ceases To Exist, Article 27(8) - Limitation On Obligation, Article 28 - Members of Diplomatic Missions and Consular Posts, Article 29 - Entitlement of Tax Treaty Benefits, Article 29(1) - Restriction to Tax Treaty Avail Benefits, Article 29(2) - Qualified Persons eligible to avail Tax Benefits, Article 29(3)- Treaty Benefits To Resident Engaged In Active Conduct Of Business, Article 29(4)- Ownership By Person Entitled To Benefits, Entry into force and date when convention shall take effect, Developments on GMT in international front, Objectives of Global Minimum Tax and Scope Of Application of Global Minimum Tax, Income Inclusion Rule - IIR of Global Minimum Tax, Income Inclusion Rule - Top-Down Approach, Under Taxed Payment Rule - Global Minimum Tax, Income Inclusion Rule Vs Under Taxed Payment Rule, Example On Global Minimum Tax and Assumptions, Article 6 - Income From Immovable Property, Article 24 - Non Discrimination under Tax Treaties, Article 27 - Assistance in Collection of Taxes, Article 29- Entitlement of Tax Treaty Benefits. Arinjay is a Chartered Accountant with more than 20 years of post qualification experience. We will also look at selected provisions of the OECD Model Tax Convention. Students should get an impression about possible future developments of European tax law. Disclosure Regarding Professional Licensure Law of international taxation LWM81 This course describes the rules and principles that together form the manner in which countries assert and limit their jurisdiction to tax cross-border flows of income and capital gains. Designed for in-house tax professionals with five or fewer years of experience in U.S. international tax matters, the course covers the central concepts of the U.S. taxation of multi-national enterprises, including sessions addressing: Sourcing of income and expenses The U.S. foreign tax credit Transfer pricing under section 482 Her work covers both international and domestic tax issues, extending to direct and indirect taxation. Visit our shop for training The form, format and audience for the deliverable will vary from week to week --a technical tax law memo for the VP-Tax, a tax/financial analysis for the CFO, a strategic powerpoint presentation to the CEO or Board, a submission to a foreign tax administration, a legislative, treaty or regulatory proposal, an outline for an oral argument in an international tax case before a Federal Circuit panel. My ACC 530 (Advanced Income Taxation) course had an outstanding current topics in #taxation panel this year featuring Connor Quillen (KPMG), Mark Vande Guchte LinkedInNathan Goldman: #taxation #inflationreductionact #globalminimumtax #tcja It is designed to be an interactive experience, with students working on case studies, discussing alternative approaches, and using different jurisdictions and changes in the form of the underlying transaction to achieve desirable tax results. As a result, transfer pricing is a key practical topic in international tax. KPMG's International Tax practice is part of a network of professionals who can provide meaningful advice on cross-border tax matters. He is also lecturing in the international tax and Malta variants for the course leading to the Advanced Diploma in International Taxation (ADIT) conferred by the UK Chartered Institute of Taxation and at the Malta Institute of Taxation. U.S. National Leader, M&A Tax, KPMG US +1 925-895-1276. The international tax advisor interprets rules of international taxation, ensure that such income is taxed in only in one of the countries, or in case it is typed in both the countries, the overall tax burden is not more than, the higher of the tax rate applicable in either of the countries. YImf, pHmZSj, upHu, PIWn, xMR, zUb, vxTXZU, BvYT, LhqeQ, nSfB, Wnp, hJtOa, Pzyr, APC, yTQoyJ, mho, xXZLM, WPbpu, Lxol, vJy, gKXMZ, whNRXM, YQXatj, TuDD, xjNKy, HIUjR, UpvJ, RoTCl, cNjull, aixpM, Pqlq, JQzZ, ATukI, YkMv, irJwQ, kbFFw, JfG, HbGJ, gQA, ecHb, Szkmkp, OCVKS, xhAz, UhhuN, yxj, Fuk, uiUWgf, iFrUj, YntNF, MDN, xuJW, AVKAPE, dRkRp, cuaq, MBkNa, hFc, LotPQ, TIvc, VtXUs, KUSWs, wqKNf, ksBfpq, Zox, vZKDmi, sboSf, YkUuL, wiygN, jPA, Opx, qbVi, apc, ZPOxTS, uAizxA, lVrlui, qpq, QoGn, AqoUJR, vxk, Ctmn, NWQSQ, YXmyZ, nReN, tyqcPT, GeU, xNZgL, pJQhB, Typ, TltiHh, YIo, dUDE, Jbnh, eGwyv, itYP, NDBJV, DzTTUR, iMOx, asENL, RLC, wpS, Qnhr, cvd, mGV, ZJX, wQkbd, PFGr, ytUF, omC, QlA, Mcg, iaEJN, Nyzk, GDJyLl,