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
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;Distinguish how hybrid entities are treated under U.S. income tax treaties;Assess whether a U.S. person’s transfer of property to a foreign corporation should generally qualify for non-recognition treatment under section 351;Assess whether a reorganization or restructuring may qualify as an “inversion” subject to the rules of section 7874
Major Topics
Section 351;Transfer Pricing;Permanent establishment;Tax Treaties;BEPS overview;Reorganizations;Stock acquisitions;Corporate formation;Inversions
