Taxation of Income Earned by Foreign Subsidiaries
Available for 1 year after purchase date
**OnDemand**
7.0 Credits
Member Price $139.00
Non-Member Price $169.00
Overview
Covering the definition of a U.S. shareholder and controlled foreign corporation (CFC) status in the context of international taxation.
Highlights
Key Topics
- U.S. outbound transactions
- Subpart F income
- Earnings and profits in an international context
- Passive Foreign Investment Companies and foreign assets
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 a controlled foreign corporation (CFC) and a U.S. shareholder.
- Identify the mechanics of Section 962 elections.
- Differentiate among Subpart F income types.
- Identify situations that create Subpart F income for a U.S. entity.
- Identify common E&P adjustments.
- Apply E&P concepts to common international tax transactions.
- Determine the consequences of PFIC ownership.
- Identify PFIC reporting requirements and foreign asset reporting requirements beyond PFICs.
Non-Member Price $169.00
Member Price $139.00