ITS Webcast series:
The Fifth Protocol of the US/Canada income tax treaty: Interpretive and structuring implications for US multinationals
Wednesday September 17, 2008
12:00 - 1:30 PM (ET)
There is no US income tax treaty of greater importance to many US multinationals than the US/Canada treaty. The Senate Foreign Relations Committee recently reported on the Fifth Protocol to the US/Canada income tax treaty with a recommendation of approval by the full Senate, the last meaningful step in the US ratification process. US ratification is expected before year end, and since Canada has already completed its ratification process, it is likely that the Protocol will come into force before January 1, 2009.
The Fifth Protocol includes important changes in the US/Canada treaty relationship that, in some ways, will make US/Canada cross-border transactions more efficient and, in other ways, will create new interpretive and structuring challenges. The 67-page US Technical Explanation of the Protocol, agreed to by the Canadian government, contains numerous insights that are relevant in interpreting the revised treaty and provides insights on interpreting provisions of other US tax treaties that are comparable to the provisions in the US/Canada treaty.
In this Webcast, Steve Nauheim, a Managing Director in PwC's Washington National Tax Services practice and a member of the US Firm's national inbound team, and Bill Holms and Steve Dunk, tax partners at PwC Canada who concentrate on US/Canada cross-border structuring, will highlight the changes brought about by the Protocol that are likely to be of greatest importance to US multinationals. They will examine the impact of the Protocol on some common cross-border structures, describe and critique the new and controversial deemed services PE provision, and discuss the revised anti-treaty shopping Limitation on Benefits provisions which will place new restrictions on the ability of US companies to claim treaty benefits.
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Please note that CPE Credit may only be awarded to participants on LIVE Webcasts.
Saratoga's Human capital effectiveness report 2008/2009
Tuesday, August 26, 2008
Despite a stumbling economy, employee productivity increased 7.6% in 2007, and the average labor cost investment required to generate a dollar of revenue decreased by 6% according to Saratoga's Human capital effectiveness report. Also, voluntary turnover remained relatively stable. HR departments will be challenged to maintain such performance in the coming year. Saratoga, an offering of PricewaterhouseCoopers and pioneer in human capital measurement, utilizes its annual Human capital effectiveness report to assist hundreds of organizations establish and sustain their measurement programs.
Saratoga's annual 2008/2009 Human capital effectiveness report reveals hundreds of metrics and thousands of unique benchmarks focused on productivity, turnover, staffing, labor cost, training, and HR cost and structure. The report contains results from over 300 organizations throughout the United States and provides organizations with the ability to make evidence-based decisions. A majority of participating organizations are in the Fortune 1000.
The archive of this webcast is coming soon!Accounting for income taxes under IFRS: Convergence & the path forward
Original Webcast: August 21, 2008
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Election to monetize unused research & AMT credits
Original Webcast: August 14, 2008
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The changing tax landscape in Massachusetts
Original Webcast: August 13, 2008
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Understanding the potential impact of Section 877A: Exit tax
Original Webcast: August 6, 2008
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Apportionment trends: The impact of states' evolving formulas
Original Webcast: July 31, 2008
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China customs and trade compliance: Challenges & best practices
Original Webcast: July 30, 2008
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Addressing recent changes to the taxation of foreign nationals in the UK
Original Webcast: July 17, 2008
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Taxation of foreign nationals in the UK slidedeck (53kb)
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Plan governance: The changing environment for governmental pension plans
Original Webcast: July 15, 2008
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Extending US equity plans to employees of foreign subsidiaries
Original Webcast: June 25, 2008
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New developments with the redesigned Form 990: Draft instructions overview
Original Webcast: June 11, 2008
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The impact of bonus depreciation
Original Webcast: March 13, 2008
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