An overview of effectively connected income, sourcing income, the branch profits tax, the Foreign Investment in Real Property Act, and more. **This product has been updated to reflect changes under H.R. 1, P.L. 119-21, commonly known as the One Big Beautiful Bill Act or OBBBA.** Tackling Inbound and Outbound Transactions The concepts of inbound and outbound transactions are critical to understanding U.S. international taxation rules. Learners differentiate transactions that generate inbound and outbound tax issues in this beginner-friendly course. A Building Block in Your International Tax Education This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation. Providing the Latest Developments The course begins with the business transactions that generate outbound tax issues in the U.S. tax system and weaves in updates from recently released Treasury Regulations. Considered are: - Concepts related to global intangible low-taxed income (and upcoming deduction amount changes), foreign tax credits, foreign currency, and foreign-derived intangible income - Inbound taxation topics such as calculating effectively connected income, sourcing income, the branch profits tax, and the Foreign Investment in Real Property Tax Act - The interpretation of tax treaties and their ability to reduce U.S. income and withholding taxes - The Base Erosion Anti-Abuse Tax This course can be purchased individually or as part of the U.S. International Tax: Core Concepts bundle. You must purchase the bundle to earn the digital badge. Who Will Benefit Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation. Key Topics - One-time transition tax - Global low-taxed intangible income (GILTI) - Foreign-derived intangible income (FDII) - Entity classification - Effectively connected income (ECI) - Branch profits tax (BPT) - U.S. withholding taxes - Foreign Account Tax Compliance Act (FATCA) - Foreign Investment in Real Property Tax Act (FIRPTA) - Base erosion anti-abuse tax (BEAT) 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).
Learning Objectives
Basic