Overview:
Enhance your value to a client or employer who operates overseas by providing advice on international taxation. This seminar gives you a comprehensive overview of the entire subject and reveals:
- How to reduce taxes on foreign earnings of US corporations
- How US tax rules affect foreign investors and the impact of various tax treaties
- How to deal with selected foreign tax systems and the key US tax forms for reporting international transactions
Objective:
To enable CPAs and other tax professionals to become more valuable to their corporations or clients by becoming knowledgeable about international taxation. Participants will gain a basic understanding of how the US taxes a domestic corporation on its foreign income and, conversely, how foreign countries tax US companies and their subsidiaries. You'll also learn how foreign investors are taxed on their US income and how such taxes are affected by various tax treaties.
Emphasis:
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US taxation of domestic corporations with foreign income
– Foreign tax credit rules
– Subpart F income rules and exceptions
– Previously Taxed Income (PTI)
– Intercompany transfer pricing
– Transfers of property to foreign corporations
– Foreign currency tax rules -
US taxation of foreign taxpayers
– Effectively connected income
– Withholding taxes on "fixed and determinable" income
– "Earnings stripping" rules
– Impact of tax treaties - Foreign tax systems in selected countries
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Selected US forms including:
– Form 1120-Schedule C
– Form 1118 (foreign tax credit)
– Forms 5471 and 5472 (reporting intercompany transactions)
– Form 1120F (US income tax return—foreign corporations)
– Form 926 (US transfer of property)
– Form 8865 (return of US person—certain foreign partnerships)
– Form 8858 (Disregarded Entities) - Impact of proposed federal legislation
