Covers U.S. international tax fundamentals beginning with defining tax systems employed around the world.
Learning 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
Major Topics
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
