Description
Covers inbound and outbound taxation topics including calculating effectively connected income, sourcing income, the branch profits tax, and the Foreign Investment in Real Property.
Designed For
- Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.
Objectives
- Identify business transactions that generate outbound tax issues.
- Recognize the approach for taxing U.S. persons with foreign activities.
- Describe the key tax reform provisions affecting outbound transactions.
- Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations.
- Recognize foreign currency issues affecting outbound transactions.
- Recognize reporting requirements applicable to U.S. persons invested in foreign corporations, foreign disregarded entities, and/or foreign partnerships.
- Recall effectively connected income (ECI) to a U.S. trade or business
- Recall the rules for sourcing of income
- Recall the rules for fixed or determinable, annual or periodic gains, profits, and income (FDAP)
- Identify a framework for determining and calculating ECI and the Branch Profits Tax (BPT)
- Indicate a general framework on the U.S. withholding taxes
Highlights
- One-time transition Tax
- GILTI
- Dividends Received Deduction
- Foreign-Derived Intangible Income
- Foreign Currency
- Entity Classification options
- Effectively Connected Income
- Branch Profits Tax
- Withholding Taxes
- Foreign Account Tax Compliance
- Foreign Investment in Real Property Tax
- Tax Treaties
- Base Erosion Anti-Abuse Tax