International Taxation - Tax Staff Essentials

A quick catch-up on international taxation

Through this course, you'll become acquainted — or re-acquainted — with essential topics in U.S. international taxation. Examples, scenarios, and expert insight make the materials a powerful resource that you can reference in your everyday work.

Topics include:

• General rules of U.S. international taxation
• The foreign tax credit
• Outbound investment through corporations
• Inbound taxation on non-residents

GILTI/NCTI, FDAP, PFIC: Simplifying the complex

The area of U.S. international taxation is replete with acronyms and complicated topics. Geared toward practitioners who need a refresh on international taxation, the course covers many of the topic area’s most important concepts:

• Default entity classification
• Income and expense sourcing
• Foreign tax credit limitations
• Overall domestic loss and overall foreign loss recapture
• Anti-deferral regimes (Subpart F, GILTI/NCTI, PFIC)
• Fixed, determinable, annual, or periodical income
• Effectively connected income

On the pulse of international taxation

H.R. 1, commonly referred to as OBBBA, and a flurry of Treasury Regulations have kept the international tax space buzzing for the past few years. Course materials capture the current international tax landscape.

Part of Tax Staff Essentials Level 4

This self-study online course is part of Tax Staff Essentials Level 4, a comprehensive learning program that provides tax managers, directors, and partners with the advanced technical training required to work with their most sophisticated clients.

This course can be purchased individually or as part of the Tax Staff Essentials Level 4 bundle.

Who Will Benefit

• U.S. tax professionals who have clients who live abroad or have foreign investments
• Industry tax staff who work for companies with global operations
• CPAs interested in growing their international tax knowledge base
• Non-U.S. accountants interested in learning about inbound transactions

Key Topics

• U.S. tax residents
• Default entity classification
• Foreign tax credit
• Net CFC tested income (formerly global intangible low-taxed income)
• Passive foreign investment companies
• Fixed, determinable, annual, or periodical income
• Effectively connected income
• H.R. 1, commonly referred to as OBBBA

Learning Outcomes

• Recognize the rules for determining who is a U.S. taxpayer.
• Recall the basic rules for allocation and apportionment of deductions.
• Recognize the need for a foreign tax credit.
• Identify the purpose of anti-deferral regimes.
• Distinguish between anti-deferral regimes that apply to controlled foreign corporations.
• Identify the U.S. taxation of fixed, determinable, annual, or periodical income of foreign persons.
• Identify the U.S. taxation of effectively connected income of foreign persons.