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As business becomes increasingly international at all levels, from the multinational to the sole proprietor, it is more likely than ever that your business (or your clients’ businesses) will need to understand international tax rules. This presentation is designed for non-international tax professionals with little or no international tax experience. The presentation will focus on the U.S. tax issues that those seeking to expand internationally will face. Presentation Objectives:
The objectives of this 90 minute audio discussion include providing participants with a conceptual understanding and practical application of the following: - International Tax Overview
- Taxation of U.S. Persons with Foreign Income
- Taxation of Foreign Persons with U.S. Income
- Structuring Foreign Operations
- Forms of doing business, including “check-the-box” planning
- Foreign income tax exposure
- Tax implications of creating foreign entities or transferring assets outside the U.S.
- Effective Tax Rate Management
- Foreign Tax Credits
- Direct and Indirect Credit
- When to claim the credit
- Overview of Foreign Tax Credit Baskets and Limitation
- Foreign Tax Credit Planning
- Controlled Foreign Corporations
- Anti-Deferral Regime, e.g., Subpart F
- Code section 956
- Previously Taxed Income
- Key Reporting Requirements
- Planning Opportunities
Upon completion of this program, participants will be able to: - Recognize international tax issues facing U.S. based multinationals in cross-border transactions, with particular emphasis on forms of doing business and tax implications of creating foreign entities or transferring assets outside the U.S.;
- Be familiar with the controlled foreign corporation regime and foreign tax credit rules; and
- Identify situations where international tax planning can add value to your company (or to your clients’ companies).
Recorded on September 23, 2009, this event is available on CD for purchase.
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