Description
Covers U.S. international tax fundamentals beginning with defining tax systems employed around the world.
Objectives
- Distinguish the differences between various types of global tax systems and certain characteristics of each
- Recall how the U.S. tax system works
- Recall entity classification and hybrids
- Recognize the different forms of operating a business in a foreign country
- Recall the concept of a permanent establishment / taxable presence in the United States and globally
- Recall U.S. income sourcing rules
- Identify general U.S. withholding tax rules
- Recognize the general function and benefits of most income tax treaties
- Recall the basics of transfer pricing rules for controlled transactions in the U.S. and globally
- Identify the key actions under the OECD Base erosion and profit shifting (BEPS) initiative
Highlights
- Tax Systems
- Inbound/Outbound Taxation
- Residency
- Foreign Tax Credits
- Entity Classification
- Subpart F Income
- Income Sourcing in U.S.
- Withholding taxes in U.S.
- Tax Treaties
- Transfer pricing