U.S. International Taxation: Overview

Authored by Robert J. Misey, Jr., J.D. , LL.M.
About this Course
This course provides an overview of U.S. international tax rules. It begins by defining U.S. and foreign persons and discussing the sourcing of income. It then looks at outbound Compliance issues, such as foreign subsidiaries of U.S. owners, foreign entity classification, PFICs, foreign tax credits, U.S. individuals working abroad, and foreign asset reporting. The course next covers outbound compliance issues, such as U.S. subsidiaries of foreign parents, foreign taxpayers with U.S. income, and disclosure of treaty-based return positions. Upon completion of this course, you will be able to: explain how the U.S. taxes international transactions of U.S. persons; recall how income is determined to be U.S. or foreign source; describe what constitutes a controlled foreign corporation; explain the qualified electing fund (QEF) method of U.S. taxation of a PFIC's undistributed earnings; list the characteristics of the PFIC special excess distribution regime; recall the title passage rule; and explain how the foreign tax credit is calculated.
$ 75.00
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NASBA Field of Study
CPE Credits
Basic understanding of corporate income taxation
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