Overview

The detailed rules you need.

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 covers effectively connected income (ECI), branch profits tax (BPT), branch level interest tax, and 1120-F with treaty-based form compliance in more detail with computational examples. It then covers detailed rules regarding sourcing, withholding tax (WHT), Foreign Account Tax Compliance Act (FATCA), and the associated compliance with examples.

Finally, it covers the definition of a U.S. Real Property Interest (USRPI) and U.S. Real Property Holding Corporation (USRPHC), the applicability of the Foreign Investment in U.S. Real Property Tax Act of 1980 (FIRPTA) to certain transactions and the exceptions, and the FIRPTA withholding rules (and exceptions).

Highlights

Key Topics

Cover sourcing
WHT rules
FATCA, and compliance

Prerequisites

None

Designed For

Who Will Benefit

Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Objectives

Learning Outcomes

Identify the existence of a U.S. trade or business
Calculate ECI of the U.S. trade or business
Calculate BPT and branch level interest
Determine what forms and schedules are needed for Inbound U.S. tax compliance
Determine the characterization of the income stream
Apply the appropriate sourcing rule to a particular income stream
Determining when a payment is considered FDAP
Identify how tax treaties impacts rate of withholding
Recall the FATCA definitions, documentation requirements, and associated requirements
Identify the associated U.S. withholding tax compliance on FDAP and ECI
Identify a USRPI and a USRPHC
Determine when FIRPTA applies and does not apply
Identify the FIRPTA withholding and notification requirements
Determine when the FIRPTA applicability and withholding exceptions apply