Fundamentals of Outbound US Rules of International Taxation 2024 (4 hours)

Overview

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).

Highlights

• The US Taxing Jurisdiction
• Sourcing Rules
• Foreign Tax Credits
• Subpart F
• Global-Intangible Low-Taxed Income
• Passive Foreign Investment Companies
• IC-DISCs

Designed For

CPAs and tax professionals that deal with international tax issues.

Objectives

• Identify issues with respect to cross border transactions
• Determine how the U.S. rules eliminate double taxation
• Recognize opportunities for tax minimization strategies

Notice

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