Overview:
Enhance your value to a client or employer who operates overseas by providing advice on international taxation. This program gives you a comprehensive overview of the entire subject and reveals:
- The old and new rules on how US corporations operating abroad are taxed
- What the new Tax Cuts and Jobs Act (TCJA) of 2017 changed regarding US multinationals
- The international tax rules that affect all companies, including the new base erosion provisions of the TCJA
- How US tax rules affect foreign investors and the impact of various tax treaties
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 companies operating in the US are taxed. You will see the effect of the TCJA on both “Outbound” and “Inbound” companies.
Emphasis:
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US taxation of domestic corporations with foreign income
– Overview of the old law as it relates to the new TCJA
– Foreign tax credit rules
– Subpart F income rules
– Previously Taxed Income (PTI)
– The transition tax to the new international taxation system– Global Intangibles Low-Taxed Income (GILTI)
– Foreign Derived Taxable Income (FDTI)
– How the TCJA changes affect Foreign Tax Credit -
TCJA changes affecting both Outbounds and Inbounds
– Base Erosion and Anti-Abuse Tax (BEAT)
– Disallowed deductions for hybrid instruments and transactions
– Transfer Pricing and OECD BEPS initiatives
– Tax treaties and withholding rules for fixed and determinable payments -
US taxation of foreign taxpayers
– Effectively connected income
– Inversions and anti-inversion legislation