Covers inbound and outbound taxation topics including calculating effectively connected income, sourcing income, the branch profits tax, and the Foreign Investment in Real Property.
Learning 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
Major Topics
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
