Description:

This program will cover U.S. Income Tax Treaties (“U.S. Treaties”) and Planning Opportunities.  This will be the first of two presentations on U.S. Treaties.  The purpose of the first program is to cover the foundational aspects to U.S. Treaties including whether a Treaty is applicable and whether U.S. statute or other law has made certain provisions of the U.S. Treaty inapplicable in the U.S. 

This program will cover the purpose of U.S. Treaties; the relationship to other Tax Agreements; development of U.S. Treaties; influence of other model treaties such as the OECD and United Nations; relationship of U.S. Treaties to U.S. domestic law; Treaty Overrides; and application to State law. 

It is important to first have a strong understanding of the authority of U.S. Treaties under U.S. law in order to determine how the provisions of the U.S. Treaties are applicable in the U.S.  Reasonable people may find it shocking that the U.S. Congress through statute can override provisions of U.S. Treaties, which are bilateral agreements with other nations, without agreement of the other nation.

The second presentation on U.S. Treaties will go through the standard provisions of U.S. Treaties, their application, and planning opportunities. 

CPE: 1.5 Credit

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https://us06web.zoom.us/j/87549607570?pwd=YUE3SDJUc0QxbFlHaWJUazRiZTZjUT09

Meeting ID: 875 4960 7570

Passcode: 951098

Christopher M. Klug

Chris serves clients with domestic and international taxation, tax controversy, corporate/business planning, mergers and acquisitions, cross-border transactions, and domestic and international estate planning.  Chris has extensive experience working with companies with domestic and international income tax planning. This work includes inbound and outbound mergers and acquisitions and other transactional tax matters. As a former tax professor, Chris has a strong background in subchapter C and S corporate taxation and partnership taxation and uses this knowledge to develop tax strategies for clients. Chris represents companies, private equity funds, hedge funds, joint ventures, real estate funds, and family offices.