Introduction to U.S. Outbound and Inbound Transactions

Overview

An overview of effectively connected income, sourcing income, the branch profits tax, the Foreign Investment in Real Property Act, and more.

Highlights

Key Topics

• One-time transition tax
• Global low-taxed intangible income (GILTI)
• Foreign-derived intangible income (FDII)
• Entity classification
• Effectively connected income (ECI)
• Branch profits tax (BPT)
• U.S. withholding taxes
• Foreign Account Tax Compliance Act (FATCA)
• Foreign Investment in Real Property Tax Act (FIRPTA)
• Base erosion anti-abuse tax (BEAT)

Prerequisites

None

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 business transactions that generate outbound tax issues.
• Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations.
• Recall effectively connected income (ECI) to U.S. trade or businesses.
• Recall the rules for sourcing of income.
• Identify a framework for determining and calculating ECI and the branch profits tax (BPT).
• Recognize a withholding agent's withholding requirements on payments made to foreign taxpayers.
• Recall the rules under the Foreign Investment in Real Property Tax Act (FIRPTA).
• Recall the base erosion anti-abuse tax (BEAT).