Exploring the tax implications of cross-border transfers between related parties.
Learning Objectives
- Learning Outcomes
- Identify a controlled foreign corporation (CFC) and a U.S. shareholder.
- Identify the mechanics of Section 962 elections.
- Differentiate among Subpart F income types.
- Identify situations that create Subpart F income for a U.S. entity.
- Identify common E&P adjustments.
- Apply E&P concepts to common international tax transactions.
- Determine the consequences of PFIC ownership.
- Identify PFIC reporting requirements and foreign asset reporting requirements beyond PFICs.
