International Tax Provisions in the 2017 Tax Cuts and Jobs Act
Authored by Robert Misey
About this Course
Topics covered include:
Deemed repatriation of accumulated earnings at the end of 2017;
Changes to sourcing rules that can result in double taxation to U.S. manufacturers;
The base erosion rules;
The participation exemption for foreign-source dividends received by C corporations;
Pass-through provisions that impact the IC-DISC benefit;
Provisions to keep intangibles in the United States.
Upon completing this course, you should be able to:
Identify the international tax provisions of the Tax Cuts and Jobs Act of 2017;
Discuss and implement planning techniques to help your clients or business;
Recognize the foreign-source dividend participation exemption;
Differentiate when deferral of the deemed repatriation tax does not apply;
Identify when a super-charged IC-DISC is more advantageous than a classic IC-DISC;
Recognize how the 2017 Tax Cuts and Jobs Act (the Act) changed the subpart F rules;
Identify why U.S. exporters will be paying higher tax under the provisions of the 2017 Tax Cuts and Jobs Act;
Differentiate when determining the amount of income from a U.S. subsidiary that is subject to the base erosion anti-abuse tax (BEAT);
Recognize the statute of limitations for the payment of the deemed repatriation tax;
Identify what the 2017 Tax Cuts and Jobs Act added to the list of 936(h)(3)(B) intangibles;
Recognize when the the downward attribution rules for foreign persons does not apply;
Identify what the 2017 Tax Cuts and Jobs Act eliminates;
Recognize what is included in Subpart F income;
Differentiate the four allocation 'baskets' for the foreign tax credit;
Identify what the new Section 163(j) does not allow for;
Recognize how base erosion abuse and BEAT are applied;
Describe what the anti-hybrid statute affects;
Differentiate statements applied to C-Corporations.
$ 34.00
Course is unavailable for purchase.
NASBA Field of Study
Taxes
Level
Update
CPE Credits
2.0
Prerequisites
Basic understanding of federal international taxation issues.
Last Updated
02/15/2018
12765
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