This program will begin the jurisdictional basis for the assertion of the U.S. taxing jurisdiction over U.S. 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).
The U.S. taxing jurisdiction. Sourcing rules. Foreign tax credits. Subpart F. Global intangible low-taxed income. Passive foreign investment companies. IC-DISCs.
Identify issues with respect to cross border transactions. Determine when the income is subject to the U.S. tax net. Recognize opportunities for tax minimization strategies.
- Robert Misey Jr
Non-Member Price $209.00
Member Price $159.00