These courses have been updated with the most recent international tax guidance, including regulations and notices addressing changes to rules for Foreign Tax Credit (FTC), Global Intangible Low-Taxed Income (GILTI) and Base Erosion and Anti-Abuse Tax (BEAT).
Learning Objectives
Distinguish the differences between various types of global tax systems and certain characteristics of each;Recognize how the Tax Cuts and Jobs Act has impacted international taxation;Identify detailed rules covering sourcing, withholding and compliance issues;Recognize the Foreign Tax Credit Rules and key concepts;Identify the accepted transfer pricing methods and when it’s appropriate to use them;Recall how U.S. tax treaties determine U.S. tax residency and how it impacts eligibility under the treaty
Major Topics
Controlled Foreign Corporations (CFCs);U.S. Shareholders;Subpart F Income;E&P;Dividends Received Deductions (DRD);Global Intangible Low-Taxed Income (GILTI);Section 965;Foreign-Derived Intangible Income (FDII);Base Erosion and Anti-abuse Tax (BEAT);Previously Taxed Income (PTI);Passive Foreign Investment Corporation (PFICs);Foreign Tax Credits (FTCs);Dual Consolidated Losses (DCLs);foreign currency,;compliance,;Effectively Connected Income (ECI);Branch Profits Tax (BPT);1120-Fs,;Foreign Account Tax Compliance Act (FATCA);Foreign Investment in Real Property Tax Act of 1980;(FIRPTA) Transfer Pricing;Tax Treaties
