This program will begin the jurisdictional basis for the assertion of the US taxing jurisdiction over US persons. After a discussion of the foreign tax credit rules and the anti-deferral regimes (Subpart F, GILTI, and PFIC), Mr. Misey will discuss export benefits (IC-DISCs and the FDII deduction).
Learning Objectives
• Identify issues with respect to cross border transactions
• Determine how the U.S. rules eliminate double taxation
• Recognize opportunities for tax minimization strategies
Major Topics
• The US Taxing Jurisdiction
• Sourcing Rules
• Foreign Tax Credits
• Subpart F
• Global-Intangible Low-Taxed Income
• Passive Foreign Investment Companies
• IC-DISCs
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