International Taxation: Outbound Transactions

Overview

The tax implications of a U.S. company's investment outside the country.

Highlights

Key Topics

• Dividends received deduction (DRD)
• Global intangible low-taxed income (GILTI)
• Base erosion and anti-abuse tax (BEAT)
• Foreign-derived intangible income (FDII)
• Section 1248 applicability
• Section 1248 calculations

Prerequisites

Basic knowledge of U.S. federal income taxation

Designed For

Who Will Benefit

Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Objectives

Learning Outcomes

• Identify global intangible low-taxed income (GILTI).
• Determine the foreign dividends-received deduction (DRD).
• Calculate the foreign-derived intangible income (FDII) deduction.
• Analyze the base erosion and anti-abuse tax (BEAT).
• Identify when earnings and profits (E&P) become previously taxed earnings and profits (PTEP).
• Identify the various types of Section 956 investments in U.S. property.
• Determine the applicability of Section 1248 to a domestic corporation.