U.S. International Tax Certificate

Overview

Updated with the most recent international tax guidance and developments, including regulations, notices, and OECD projects.

Highlights

Key Topics

• Residency
• Regimes including Subpart F income and global low-taxed intangible income (GILTI)
• Organization for Economic Co-operation and Development (OECD) initiatives
• Effectively connected income (ECI)
• Controlled foreign corporations
• Foreign tax credit (FTC)
• Transfer pricing methods
• Formations, reorganizations, and liquidations

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

• Distinguish between various types of global tax systems and certain characteristics of each.
• Identify the key actions under the Organisation for Economic Cooperation and Development (OECD) base erosion and profit-shifting (BEPS) initiative.
• Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations.
• Identify a controlled foreign corporation (CFC) and a U.S. shareholder.
• Recall the general foreign tax credit (FTC) rules.
• Identify a qualified business unit (QBU) under Section 989.
• Identify the accepted transfer pricing methods and recognize when each is appropriate to use.
• Identify the tax consequences of an exit event, such as liquidation, related-party sale, and third-party sale (with availability of certain elections).