Covering the definition of a U.S. shareholder and controlled foreign corporation (CFC) status in the context of international taxation.
Learning Objectives
- Learning Outcomes
- Identify business transactions that generate outbound tax issues.
- Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations.
- Recall effectively connected income (ECI) to U.S. trade or businesses.
- Recall the rules for sourcing of income.
- Identify a framework for determining and calculating ECI and the branch profits tax (BPT).
- Recognize a withholding agent’s withholding requirements on payments made to foreign taxpayers.
- Recall the rules under the Foreign Investment in Real Property Tax Act (FIRPTA).
- Recall the base erosion anti-abuse tax (BEAT).
