International Taxation: Outbound Transactions
Overview:
Build a solid foundation.
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 the other major areas of U.S. international tax reform such as dividends received deduction (DRD), Global Intangible Low-Taxed Income (GILTI), Base Erosion and Anti-abuse Tax (BEAT), Foreign-Derived Intangible Income (FDII), and Section 965. It then details Section 956, investment in U.S. property by a Controlled Foreign Corporation (CFC). Finally, it covers Section 959, previously taxed income.
Discussion will also focus on general operating rules, consequences of previously taxed income ( PTI) distributions, and successor rules. Finally, this module will cover section 1248 applicability in bother taxable and non-taxable transactions with examples.
Objectives:
Learning Outcomes
- Identify new foreign dividends received deduction
- Recall the new Global Intangible Low-Tax Income basket
- Identify the Foreign Derived Intangible Income deduction
- Recall the Base Erosion Anti-Abuse Tax
- Identify the various types of Section 956 investments in U.S. property
- Apply the exceptions to Section 956
- Calculate Section 956
- Apply Section 960(c)
- Identify when E&P becomes PTI
- Determine the tax consequences upon a distribution of PTI
- Identify the impact PTI has on outside tax basis in CFC stock
- Determine when Section 1248 applies
- How section 1248 is calculated.
Major Topics:
Key Topics
- GILTI
- FDII
- BEAT
- DRD
- Section 965
- Section 956 - types
- Calculation
- 960(c)
- Section 959 - PTI distributions and implications
- Section 1248 applicability
- Section 1248 calculations