Fundamentals of Outbound US Rules of International Taxation 2024

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

Prerequisites

None

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

Preparation

None