Critical steps in the risk management and insurance planning process are explored, from insurance contracts and annuities to deferred compensation and closely held businesses.
Learning Objectives
- Learning Outcomes
- Recognize the rules for determining who is a U.S. taxpayer.
- Recall the basic rules for allocation and apportionment of deductions.
- Recognize the need for a foreign tax credit.
- Identify the purpose of anti-deferral regimes.
- Distinguish between anti-deferral regimes that apply to controlled foreign corporations.
- Identify the U.S. taxation of fixed, determinable, annual, or periodical income of foreign persons.
- Identify the U.S. taxation of effectively connected income of foreign persons.
