Overview

Differ from the "old" rules.

This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation. This course can be purchased individually or as part of the U.S.International Tax: Inbound and Outbound Transactions bundle. You must purchase the bundle to earn the digital badge.

This CPE self-study course focuses on determining U.S. shareholder and Controlled Foreign Corporation (CFC) status under the new rules from tax reform. There is also discussion on how such rules differ from the "old" rules.

The course also provides a detailed session on the operating rules of subpart F income but not including section 956 and Global Intangible Low-Taxed Income (GILTI) inclusions. There is detailed discussion on international topics regarding calculating and reporting E&P for U.S. federal income tax purposes, as well as practical examples and application.

Also discussed in detail are international topics regarding Passive Foreign Investment Companies (PFICs) and foreign asset reporting for U.S. federal income tax purposes, as well as practical examples and application.

Highlights

Key Topics

Determination of CFC and U.S. Shareholders
Application of constructive ownership rules
New downward attribution
Section 962
All forms of subpart F income (FPHCI, sales, and services)
Operating rules
Exceptions
Why is E&P Important
Overview of the E&P Computation
Common E&P Adjustments
Applying E&P to Your Clients: What to look for and real-world examples
Reporting E&P on Form 5471
Tax issues resulting from E&P issues
Definition of a PFIC and Examples
Shareholder Taxation of PFICs without QEFs
Shareholder Taxation of PFICs with QEFs
Mark-to-market Elections (Mark-to-market 1296)
Retroactive Relief
Foreign Asset Reporting Requirements
Excess Distribution 1291
Qualified Electing Funds 1293 & 1295
FBARs and 8938s

Prerequisites

None

Objectives

Learning Outcomes

Identify a CFC and a U.S. shareholder
Apply constructive stock attribution rules properly (*Tax reform)
Distinguish how rules around indirect and direct ownership is applied
Section 962 Elections
Differentiate the different types of subpart F income
Identify situations that would create subpart F income for a U.S. entity
Calculate subpart F income for specific scenarios
Apply specific rules providing exceptions and limitations for subpart F income
Identify the importance of E&P in an International Context
Recall E&P
Calculate Common E&P Adjustments
Apply E&P Concepts to common International Tax transactions
Determine when you have PFICs
Recognize the consequences of PFIC ownership
Differentiate the tax implications of PFIC elections
Recall PFIC reporting
Recognize Foreign Asset reporting requirements beyond PFIC