Highlights
• Withholding on dividends, interest, rents, royalties, and compensation
• Withholding rules on foreign investment in US Real Estate
• 163(j) and Base Erosion Anti-abuse Tax restrictions on repatriation
• Foreign Persons with a US Trade or Business
• Taking advantage of tax treaties
• Tax-Advantaged Transfer Pricing
• IRS Audit Tools for Foreign-Owned Corporations