Overview:
This program will begin the jurisdictional basis for the assertion of the US taxing jurisdiction over US 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).
Objectives:
• Identify issues with respect to cross border transactions • Determine how the U.S. rules eliminate double taxation • Recognize opportunities for tax minimization strategies
Major Topics:
• The US Taxing Jurisdiction • Sourcing Rules • Foreign Tax Credits • Subpart F • Global-Intangible Low-Taxed Income • Passive Foreign Investment Companies • IC-DISCs
Major Topics:
• The US Taxing Jurisdiction • Sourcing Rules • Foreign Tax Credits • Subpart F • Global-Intangible Low-Taxed Income • Passive Foreign Investment Companies • IC-DISCs
Designed For:
CPAs and tax professionals that deal with international tax issues.
Prerequisites:
None