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
Determine U.S. shareholder and CFC status under the new rules from tax reform.;Recognize the operating rules of subpart F income.;Recognize the Foreign Tax Credit Rules and key concepts.;Identify issues related to dual consolidated losses, foreign currency rules and regimes under U.S. tax law.;Identify detailed rules covering sourcing, withholding and compliance issues.
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)
