Description
This program will begin the jurisdictional basis for the assertion of the US taxing jurisdiction over US persons. After a discussion of the foreign tax credit rules and the anti-deferral regimes (Subpart F, GILTI, and PFIC), Mr. Misey will discuss export benefits (IC-DISCs and the FDII deduction).
Presenters - Robert J. Misey Jr
Designed For
Designed For: CPAs and tax professionals that deal with international tax issues.
Role Level - Manager/Senior Manager; Director; Executive/VP
Objectives
- Identify issues with respect to cross border transactions
- Determine how the U.S. rules eliminate double taxation
- Recognize opportunities for tax minimization strategies
Highlights
- The US Taxing Jurisdiction
- Sourcing Rules
- Foreign Tax Credits
- Subpart F
- Global-Intangible Low-Taxed Income
- Passive Foreign Investment Companies
- IC-DISCs
Advanced Prep
None
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Leaders
CALCPE Panel
No Biography Available