About this Course
Former IRS attorney and noted international tax advisor, Robert Misey, J.D., LL.M., M.B.A. and author of the treatise, U.S. Taxation of International Transactions published by Wolters Kluwer, will review the rules, tips and traps of entity choice for foreign operations so you get the most favorable results. Mr. Misey will also examine the technical guidance provided by the IRS and share their experience in how the IRS applies the rules, focusing on the immediate tax consequences of the election. Topics covered include: Fundamentals of "checking the box", Timing of check-the-box elections, Domestic tax implications of checking the box, International tax implications of checking the box, Completing a Form 8832 "Check-the-box election", International tax compliance for a "checked" entity - Form 8858.
After completing this course , you should be able to: Recognize the tax law, requirements and procedures for making check-the-box elections, Identify opportunities where making a check-the-box election will save taxes, Recognize which default rules with respect to foreign entity election apply, Identify the general requirements when making a late election, Differentiate statements regarding an entity taxed as a corporation electing to be treated as a partnership, Recognize the characteristics of a Section 331 liquidation of a foreign corporation
Identify which types of organization foreign tax credits are available for, Recognize which form is used for transfer pricing audits and also includes four filing categories, Describe matters of when an organization is an entity separate from its owners
Identify the grandfathered provisions for eligible entities are available for specific years, Recognize the due date of an election effective on the first day of a taxable year, Identify late election methods, Differentiate considerations for an S election for an LLC taxed as a partnership to minimize self-employment tax and new Medicare tax risk
Describe which conversion an S Corporation acquisition should utilize, Recognize the decisions involved to "check-the-box" weighing deferral versus which type of tax rate, Differentiate credit conversions and checking-the-box for foreign corporations.