This course offers a deep dive into the tax treatment, issues, and planning techniques involved in international business transactions. From the taxation of U.S. taxpayers conducting business abroad to inbound rules for non-U.S. taxpayers in the United States, learners will explore concepts such as transfer pricing, controlled foreign corporations, foreign tax credits, and more.
Whether you are new to international taxation or seeking to expand your knowledge, this course provides a comprehensive understanding of the complexities involved in conducting business internationally.
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The course is divided into four modules, covering topics such as international taxation principles, inbound taxation, controlled foreign corporations, and the foreign tax credit.
Module 1 provides an introduction to international taxation, covering jurisdictional principles, sourcing, and the fundamentals of U.S. taxation of international transactions. Learners will delve into the theories of international taxation, tax residency, and the source of income rules.
Module 2 focuses on inbound taxation, tax treaties, transfer pricing, and export incentives. Learners will explore concepts such as branch profits tax, U.S. tax treaties, base erosion anti-abuse tax, and foreign derived intangible income.
Module 3 delves into controlled foreign corporations and current income inclusions. Topics covered include an introduction to subpart F, types of subpart F income, global intangible low-taxed income (GILTI), and passive foreign investment company (PFIC).
Module 4 explores the foreign tax credit, including creditable foreign taxes, limitations, and the GILTI foreign tax credit limitations. Learners will gain a comprehensive understanding of the foreign tax credit system and its implications for international transactions.
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