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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 some international tax experience. The presentation will focus on the U.S. tax issues that those seeking to expand internationally will face. This programs offers a more in-depth overview of international taxation than the basic “Introduction to U.S. International Tax for Non-International Tax Professionals” and is designed as either a stand alone program or a continuation of the introductory course. Presentation Objectives:
The objectives of this 90 minute audio discussion include providing participants with a conceptual understanding and practical application of the following: - Outbound Transfers under Code section 367
- The Foreign Tax Credit
- Sourcing Rules
- Expense Allocation and Apportionment
- Foreign Tax Credit Planning, e.g., increasing foreign source income
- Subpart F and PFIC Rules
- Branch Rules
- Subpart F Planning
- Code section 1248
- Code section 482 and Transfer Pricing Overview
- Tax Treaties and Code section 894
- Outbound Tax Planning
- U.S. Taxation of Foreign Persons
Upon completion of this program, participants will be able to: - Have a deeper understanding of international tax issues facing U.S. based multinationals in cross-border transactions, with particular emphasis on Code section 367; the calculation of the foreign tax credit and planning ideas to maximum the ability to use the credit; planning to avoid subpart F inclusions; dispositions of controlled foreign corporations; transfer pricing; tax treaties and permanent establishment; and U.S. taxation of foreign persons.
- Use tax planning ideas to address various issues that arise from U.S. multinational investing in foreign jurisdictions.
Recorded on October 7, 2009, this audio event is available on CD for purchase.
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