A detailed overview of dual consolidated loss, foreign currency, and international tax reporting rules.
Learning Objectives
- Learning Outcomes
- Identify the tax consequences of having U.S. effectively connected income (ECI).
- Determine whether an activity constitutes U.S. trade or business.
- Determine the branch profits tax (BPT) and branch-level interest.
- Identify the basics of tax withholding for nonresident aliens and taxation under the Foreign Account Tax Compliance Act of 2010 (FATCA).
- Identify how to determine the character and source of income for different payment types.
- Identify a withholding agent and the rules that apply to withholding agents.
- Determine when the Foreign Investment in Real Property Tax Act (FIRPTA) applies and does not apply.
- Identify FIRPTA exclusions and exceptions with respect to U.S. real property interests (USRPIs).
