Part I:;Distinguish the differences between various types of global tax systems and certain characteristics of each;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;Part 2:;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

Tax Systems;Inbound/Outbound Taxation;Residency;Foreign Tax Credits;Entity Classification;Subpart F Income;Taxable presence in U.S;Income Sourcing in U.S.;Withholding taxes in U.S.;Tax Treaties;Transfer pricing;Key Actions under OECD BEPS initiative;FDII;GILTI