U.S. Source Withholding Tax Rules and Tax Treaty Application (Completed)

Date: Monday, November 29, 2021
Instructor: Adnan Islam
Begin Time:  9:00am Pacific Time
10:00am Mountain Time
11:00am Central Time
12:00pm Eastern Time
CPE Credit:  2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC

This course will cover a discussion of the U.S. withholding tax rules under Chapter 3 (FDAP) of the Internal Revenue Code (IRC), corresponding IRS forms/compliance relating to withholding tax on FDAP, and (Income) Tax Treaty Application (e.g., DTT/Convention).

Who Should Attend
Experienced tax staff through tax director level interested in or already practicing U.S. international income taxation.

Topics Covered

  • What are the fundamental U.S. withholding tax rules under Chapter 3 of the IRC?
  • What is FDAP?
  • What are the basic IRS compliance and potential documentation requirements for U.S. withholding taxation under Chapter 3 of the IRC?
  • Tax treaty application and mitigation of the statutory U.S. withholding tax rate

Learning Objectives

  • Identify the Chapter 3 U.S. withholding tax rules
  • Recognize items of FDAP income
  • Recognize IRS forms, compliance, and/or documentation that may be required to report and comply with the U.S. withholding tax rules under Chapter 3 of the IRC
  • Recognize that U.S. has income tax treaties (e.g., DTTs or Conventions) with many countries, and applicable treaties may mitigate or eliminate the statutory rate of U.S. source withholding


Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Read IRC Sections 871, 881, 1441, and 1461. Read Form 1042-S Instructions.

Advance Preparation

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