U.S. International Tax: Core Concepts

Overview

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

Highlights

Key Topics

• Residency
• Foreign tax credits (FTCs)
• Entity classification
• Regimes including Subpart F income and global low-taxed intangible income (GILTI)
• Transfer pricing
• Effectively connected income (ECI)
• Base erosion anti-abuse tax (BEAT)
• Tax treaties

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

• Distinguish between various types of global tax systems and certain characteristics of each.
• Recall the concept of a permanent establishment and taxable presence in the United States and globally.
• Recall the basics of transfer pricing rules for controlled transactions in the United States and globally.
• 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.
• Recall effectively connected income (ECI) to U.S. trade or businesses.
• 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).