U.S. International Tax: Inbound and Outbound Transactions

Overview

Providing an in-depth understanding of essential international tax topics, including effectively connected income, the foreign tax credit, global intangible low-taxed income, the base erosion and anti-abuse tax, and more.

Highlights

Key Topics

• Controlled foreign corporations
• Subpart F income
• Global intangible low-taxed income (GILTI)
• Base erosion and anti-abuse tax (BEAT)
• Foreign-derived intangible income (FDII)
• Foreign tax credit (FTC)
• Calculation of dual consolidated losses (DCLs)
• Effectively connected income

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.
• Differentiate among Subpart F income types.
• Identify global intangible low-taxed income (GILTI).
• Calculate the foreign-derived intangible income (FDII) deduction.
• Recall the general foreign tax credit (FTC) rules.
• Recall the purpose of dual consolidated loss (DCL) rules.
• Identify a qualified business unit (QBU) under Section 989.
• Identify the tax consequences of having U.S. effectively connected income (ECI).