Fundamentals of Outbound U.S. Rules of International Taxation

Description

This program will begin the jurisdictional basis for the assertion of the U.S. taxing jurisdiction over U.S. persons. After a discussion of the foreign tax credit rules and the anti-deferral regimes (Subpart F, GILTI, and PFIC), Mr. Misey will discuss export benefits (IC-DISCs and the FDII deduction).

Highlights

• The U.S. Taxing Jurisdiction

• Sourcing Rules

• Foreign Tax Credits

• Subpart F

• Global-Intangible Low-Taxed Income

• Passive Foreign Investment Companies

• IC-DISCs

Objectives

• Identify issues with respect to cross border transactions

• Determine how the U.S. rules eliminate double taxation

• Recognize opportunities for tax minimization strategies

Designed For

CPAs