Expanding and investing in international business may seem like a complex and risky venture, but the potential rewards and benefits are too great to ignore. Fortunately, this self-study webinar will be led by international taxation and investment specialists who will demonstrate how you and your company can take this next big step forward. Areas of discussion include:
- Choosing the most appropriate business entity
- Understanding the application of special regimes
- Navigating the rules relating to outbound non-recognition transfers of assets
- US shareholders’ GILTI inclusion
To provide tax professionals with the necessary information to determine how their company can take advantage of the growing opportunities available in international expansion and investment.
SPEAKERS:
Michael Hirschfeld, Managing Director, US National Tax office, Andersen
Joe Calianno, Managing Director, US National Tax practice, Andersen
- Check-the-Box Regulations
- Flow-through Entities
- Foreign Based Company Sales and Services Income
- Exceptions and Special Rules Relating to Subpart F
- The GILTI Formula
- Passive Foreign Investment Companies (PFIC)
- Threshold Requirements
- Treaty Benefits
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Application of US Tax Treaties
– Dividend income
– Trade income
– Business income - Transfer Pricing and Compliance
• Understand the key considerations when choosing an entity to conduct business internationally
• Identify the default classifications for foreign entities under US "check-the-box" regulations
• Understand the concept of US shareholder GILTI inclusion and its components
• Recognize the US tax rules applicable to controlled foreign corporations (CFCs)
• Recognize the Passive Foreign Investment Company (PFIC) tests
• Identify the key income types under Subpart F
• Understand tax treaties and their role in reducing international tax barriers
• Understand transfer pricing rules and their application to international transactions