Part I:

• Distinguish the differences between various types of global tax systems and certain characteristics of each
• Recall entity classification and hybrids
• Recognize the different forms of operating a business in a foreign country
• Recall the concept of a permanent establishment / taxable presence in the United States and globally
• Recall U.S. income sourcing rules
• Identify general U.S. withholding tax rules
• Recognize the general function and benefits of most income tax treaties
• Recall the basics of transfer pricing rules for controlled transactions in the U.S. and globally
• Identify the key actions under the OECD Base erosion and profit shifting (BEPS) initiative

Part 2:

• Identify business transactions that generate outbound tax issues.
• Recognize the approach for taxing U.S. persons with foreign activities.
• Describe the key tax reform provisions affecting outbound transactions.
• Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations.
• Recognize foreign currency issues affecting outbound transactions.
• Recognize reporting requirements applicable to U.S. persons invested in foreign corporations, foreign disregarded entities, and/or foreign partnerships.
• Recall effectively connected income (ECI) to a U.S. trade or business
• Recall the rules for sourcing of income
• Recall the rules for fixed or determinable, annual or periodic gains, profits, and income (FDAP)
• Identify a framework for determining and calculating ECI and the Branch Profits Tax (BPT)
• Indicate a general framework on the U.S. withholding taxes

• Tax Systems
• Inbound/Outbound Taxation
• Residency
• Foreign Tax Credits
• Entity Classification
• Subpart F Income
• Taxable presence in U.S
• Income Sourcing in U.S.
• Withholding taxes in U.S.
• Tax Treaties
• Transfer pricing
• Key Actions under OECD BEPS initiative
• FDII
• GILTI