On-Demand


51.5 CPE

U.S. International Tax Certificate

On-Demand
51.5 CPE

Learning Objectives

  • Distinguish between various types of global tax systems and certain characteristics of each.
  • Identify the key actions under the Organisation for Economic Cooperation and Development (OECD) base erosion and profit-shifting (BEPS) initiative.
  • Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations.
  • Identify a controlled foreign corporation (CFC) and a U.S. shareholder.
  • Recall the general foreign tax credit (FTC) rules.
  • Identify a qualified business unit (QBU) under Section 989.
  • Identify the accepted transfer pricing methods and recognize when each is appropriate to use.
  • Identify the tax consequences of an exit event, such as liquidation, related-party sale, and third-party sale (with availability of certain elections).

Major Topics

  • Residency
  • Regimes including Subpart F income and global low-taxed intangible income (GILTI)
  • Organization for Economic Co-operation and Development (OECD) initiatives
  • Effectively connected income (ECI)
  • Controlled foreign corporations
  • Foreign tax credit (FTC)
  • Transfer pricing methods
  • Formations, reorganizations, and liquidations

CPE Credits Available

51.5 CPE
51.5
Taxes

Things to Know About This Course

Course Level

  • Intermediate

Professional Area of Focus

  • Tax
  • International Tax

Prerequisites

Basic knowledge of U.S. federal income taxation

Intended Audience

Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation

Provider

AICPA - Durham

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