F. Hale Stewart JD, LL.M.
Tax Attorney, The Law Office of Hale Stewart
Mr. Stewart has a masters in both domestic (US) and international taxation from the Thomas Jefferson School of Law where he graduated magna cum laude. Is currently working on his doctoral dissertation. He has written a book titled US Captive Insurance Law, which is the leading text in this area.

He forms and manages captive insurance companies and helps clients in international tax matters, US entity structuring, estate planning and asset protection.

Program Description: more and more, companies’ and individual’s tax matters cross borders. These multi-jurisdictional transactions and structures are typically governed by tax treaties. Although there are three basic model treaties (the OECDs, the US’ and the UNs), each uses many of the same concepts. This introductory course will provide the viewer with a basic understanding of these se concepts.

Program Level: basic/introductory
Prerequisites: none
Advance Preparation: none
Learning Objections: to provide the viewer/participant with a basic, rudimentary knowledge of the OECD Model Tax Treaty.

The program will cover the following concepts:
1. Introduction: a history of tax treaties, taxing nexus, treaty applications and taxes covered
2. Residency for a Person
3. Residency for a Corporation
4. Permanent Establishment
5. Income Statement Items