Effectively Connected Income: Defining a U.S. Trade or Business, FDAP Income, FIRPTA, U.S. Income Tax Treaties
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss defining, taxing, and withholding obligations of effectively connected income (ECI). Our panel of astute foreign tax specialists will review trade or business income requirements, fixed, determinable, annual, or periodic (FDAP) income, the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), and how U.S. income tax treaties treat ECI.
Outline
- Statutory framework: IRC §864(c)
- Comparison with FDAP income
- What is a trade or business
- Special situations
- Impact of U.S. income tax treaties
- Claiming ECI income
- Payor reporting of ECI income
Benefits
The panel will cover these and other critical issues:
- The statutory framework for IRC Section 864(c)
- What is a trade or business?
- How FDAP income compares with effectively connected income
- The impact of U.S. income tax treaties on ECI
- Withholding and reporting requirements for ECI
Faculty
C. Edward (Ed) Kennedy, Jr., CPA, JD
Managing Director
C Edward Kennedy Jr
Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing... | Read More
Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Mr. Kennedy has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm. He is a frequent speaker in the areas of international tax compliance and reporting obligations U.S. information reporting requirements for foreign assets and foreign entities, U.S. tax implications of foreign pension and social security plans, and U.S. income and social tax treaty planning. Mr. Kennedy is a member of the Texas Bar and is licensed as a certified accountant in Georgia and Texas. He has a B.A. from Furman University and a J.D. from Vanderbilt University School of Law.
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Kimberlee S.P. Murphy, CPA, CGMA, MBA
Partner, Market Leader, International Services
Withum Smith+Brown
Ms. Murphy is Withum’s International Services Market Leader with over 30 years of accounting and tax... | Read More
Ms. Murphy is Withum’s International Services Market Leader with over 30 years of accounting and tax experience, and expertise in International Structuring, FATCA, Transfer Pricing, Inbound and Outbound Transactions, Expatriation Taxation/Global Mobility, and Executive Compensation Planning. She serves on HLB’s International Tax Committee and has co-chaired the HLB North America Tax Services Group. Ms. Murphy has authored articles for numerous local publications and has been a frequent lecturer on tax, business and financial matters to the general public, and professional and business organizations. She coordinates and conducts continuing professional education training on all types of tax issues for the firm’s accountants and outside professionals.
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