Surgent's U.S. Taxation of Foreign Corporations: A Case Study Approach

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Location: Online

3Credits

Technical Business

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Product Code: SU24-TFC3-SSWC

Level: Basic

Vendor: Surgent

Field of Study: Taxes

Overview:

This course is a case study designed to provide a comprehensive overview of U.S. taxation of a foreign corporation. Using a specific example, the course will walk through step-by-step mechanics on how to calculate the income inclusions and foreign tax credits under GILTI (Global Intangible Low-Taxed Income), Subpart F, and PFIC (Passive Foreign Investment Company) regimes. The case study will further evaluate tax impact of subsequent distributions from the foreign corporation and sales of its stock. A compare-and-contrast approach will highlight the different outcomes of these regimes for individuals and for C corporations, empowering participants to advise their clients on the most tax efficient way to structure their international investments.

Objectives:

Explain the similarities and differences between GILTI, Subpart F, and PFIC regimes
Understand the mechanics of income inclusions and foreign tax credits available under GILTI, Subpart F, and PFIC regimes
Compare and contrast the overall tax liability under different circumstances
Identify tax planning opportunities for income from foreign corporations

Major Topics:

Understand how to approach and analyze the U.S. taxation of foreign corporations
Using an example, calculate GILTI, Subpart F, and PFIC income inclusions for an individual and C corporation
Determine how much foreign tax credit can be claimed against such income inclusions
Determine how subsequent dividend distributions from the foreign corporation are taxed
Calculate capital gain on the disposition of the foreign corporation
Discuss the impact of Section 962 election
Compare different outcomes under GILTI, Subpart F, and PFIC regimes for individuals and corporations
Identify basic strategies for managing tax liabilities related to foreign corporations

Designed For:

Any tax practitioner with clients invested in a foreign corporation

Prerequisite:

A basic understanding of the tax rules relating to individual and corporate income tax

Additional Info:

You will receive an email from [email protected] with instructions on how to log onto your course shortly. If you do not receive the email within the hour, please check your spam filter.

For technical support, registration questions or other customer service-related inquiries, please call (800) 778-7436 or email [email protected]. Phones are staffed from 8:30 a.m. to 5:00 p.m. Eastern Time, Monday through Thursday, and 8:30 a.m. to 4:00 p.m. Eastern Time on Friday.