Narelle MacKenzie
CPA, Narelle MacKenzie CPA
With over 25 years of experience in international taxes, Narelle MacKenzie is a well known international tax consultant. Her experience working with, or for, multinational companies enables her to develop strategic and practical solutions to minimize worldwide tax burdens. Ms. MacKenzie is also an International Tax lecturer at San Diego State University (SDSU), first appointed in 2007. She is located in San Diego, CA and works with CPAs, attorneys, and in-house tax departments worldwide.

She has worked in both public accounting and industry for employers such as Goodrich Corporation (a Fortune 500 company that was acquired by United Technologies), PricewaterhouseCoopers LLP, and Toyota Australia. Her business experience has covered diverse industries and activities, including supply chain activities and initiatives, identification and implementation of new manufacturing facilities, establishing representative offices, secondment arrangements, customer sales and support initiatives and general cross-border issues.

As well as lecturing at SDSU, she is a highly sought after speaker, course instructor and guest lecturer and has presented at many and diverse conferences including CalCPA, the ABA, CITE, AWSA and PwC.

She is a Past President of CalCPA (San Diego chapter), and currently serves on the Audit Committee for St James by the Sea, La Jolla.

Ms. MacKenzie is an Australian CPA and a California CPA.

COURSE PROGRAMME
The structure of the US tax system

• Federal taxation vs. state and local taxation
• The federal tax system: the Internal Revenue Code

US federal income taxation: overview

• Basic rule: taxation of worldwide income of US persons
• Individuals
• Corporations
• Partnerships
• Trusts and estates
• Classification of business entities: the “check the box” regime
• Basic rules regarding taxation of non-US persons
• Source of income: section 861 et seq.

Inbound investment

• Non-US person engaged in the conduct of a US trade or business
• Non-US persons not engaged in the conduct of a US trade or business
• Foreign Investment in Real Property Tax Act
• Special US tax treaty issues: Limitation of benefit articles, saving clauses, treaty overrides
• Specific anti-avoidance rules: interest-stripping and anti-conduit regulations

Outbound investment

• Foreign tax credit
• Anti-deferral rules
• Outbound transfers: Code section 367

Other issues

• Transfer pricing rules: Code section 482 and regulations
• Anti-avoidance: general case law doctrines and main statutory provisions
• Estate and Gift Tax
• Indirect Taxes: customs duties; state and local sales taxes