A detailed overview of dual consolidated loss, foreign currency, and international tax reporting rules. **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.** Mastering foreign loss tax implications Dual resident corporations may be subject to the dual consolidated loss (DCL) rules that the U.S. Congress implemented in the 1980s. This course focuses on the complexities of DCLs, including their computation and the events that trigger DCL recapture. Updated for OECD Pillar 2 developments We’ve updated this course to discuss the interaction between DCLs and Pillar 2 of the Organisation for Economic Co-operation and Development (OECD) base erosion and profit shifting (BEPS) plan. Facing foreign currency woes This course also covers various foreign currency rules and regimes under U.S. tax law. It provides a complete discussion of: - Interactions of foreign currency rules - Qualified business units - Determination of a foreign entity’s functional currency Complying with international tax reporting requirements This course also provides a detailed session on U.S. federal income tax compliance, focusing on outbound transactions. Learners are exposed to the required forms to be filed and the failure-to-file consequences. Part of a comprehensive 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. This course can be purchased individually or as part of the U.S. International Tax: Inbound and Outbound Transactions 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 - Calculation of dual consolidated losses (DCLs) - DCL recapture triggering events - Foreign currency transaction rules - Qualified business units - International tax reporting requirements Learning Outcomes - Recall the purpose of dual consolidated loss (DCL) rules. - Recognize triggering events that give rise to a DCL recapture. - Recognize DCL reporting requirements. - Analyze the interaction of foreign currency transaction rules. - Identify a qualified business unit (QBU) under Section 989. - Determine functional currency for foreign entities under Section 985. - Recognize the complexities of branch and disregarded entity (DRE) currency transactions under Section 987.
Learning Objectives
Intermediate