Objectives
• Identify basic foreign tax law fundamentals to properly serve clients that require international tax compliance.
• Recognize how to comply with U.S. tax reporting requirements for inbound and outbound transactions and operations.
• Identify how to source income to a foreign jurisdiction.
• Determine the required allocation and apportionment of deductions to foreign sourced income.
• Analyze which foreign taxes are creditable against U.S. taxes.
• Recognize how to Report foreign bank accounts and investments in jurisdictions including FATCA rules.
• Identify the U.S. tax reporting requirements for foreign affiliates.
• Recognize how to structure transactions and/or business operations of foreign-based service businesses entering the United States.
• Evaluate the effect of treaties on the taxation of your client's foreign based income activities.
Major Topics
• Receipts in foreign currency
• Allocation and apportionment of deductions
• U.S. foreign tax credit – fundamentals and special rules
• Initiation of foreign operations
• Foreign branches and affiliated companies
• Sale of use of tangible property
• Foreign business operations in the United States
• Foreign business sales of tangible property in the United States
• Foreign business provision of services in the United States
• Exploitation of business assets outside of the United States
• Use of foreign tangible/intangible property in the United States
• U.S. withholding taxes on foreign businesses
Prerequisite
Strong knowledge of U.S. Income taxation
