International Taxation: Inbound Transactions
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).
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
Major Topics:
Key Topics
- Cover sourcing
- WHT rules
- FATCA, and compliance
Designed For:
Who Will Benefit
- Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.