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Base Erosion and Profit Sharing  

CATEGORY: Taxation
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9 CPE Credits

Although this course does not deal directly with domestic federal or state income tax provisions, the course deals with one of the most significant tax developments since the growth of transfer pricing legislation around the world. The OECD Reports on Base Erosion and Profit Shifting (BEPS) will have tax consequences around the world for decades in the future as more and more countries adopt some, many, or most of the recommendations within each of the individual reports.

Many have argued that the Reports will have little effect in the US. This is entirely false. Even if the US adopts none of the BEPS recommendations, any US based multinationals will be doing business in jurisdictions where, in fact, some, many, or most of the BEPS provisions will be implemented. Such legislative changes adopted abroad, will no doubt cast a constant need to monitor legal structures and transactions which span across borders.

Furthermore, it is not even safe to assume the US will not adopt any such provisions. Within a short time after the OECD's issuance of the BEPS reports, the US has issued regulations concerning country-by-country transfer pricing documentation as well as debt versus equity. The US has also made revisions to the US Model Income Tax Treaty.

Thus, it is imperative that any tax professional in the US be familiar with the contents of the OECD BEPS reports in order to gain an understanding how these recommendations will influence fiscal policy officials both in the US and abroad. The OECD BEPS Reports will have an on-going impact for several decades to come.

This course is most appropriate for the professional with detailed knowledge in base erosion and profit sharing who may be at a mid-level position within an organization with operational or supervisory responsibilities, or both.

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