A comprehensive overview of US international tax focusing on inbound and outbound investment by corporations
This course is ideal for those new to US international tax or who work in the area less frequently. This course is generally run in person and the online version aims to replicate that experience as closely as possible. As a guide to who should attend, many previous participants at the in-person courses work in the tax departments of US companies outside the US and wish to broaden their understanding of the principles and/or the work done by their colleagues in the United States.
It is also ideal preparation for those planning to take the Advanced Diploma in International Taxation exam US option but who have little existing knowledge and need an introduction to a very different tax system before tackling the more complex areas that our in-depth course addresses. (The tutor will assume that participants are familiar with international tax concepts generally.)
The compact, three-day agenda has been converted into six, two-hour sessions that will run from 4-6pm GMT.
Please note that the course focuses on corporate tax issues.
Call +44 (0)7736 298951 or email deborah@djhinternationaltax.com for more details.
Tuesday, 2 March
I. The structure of the US tax system and federal overview
A: US taxation in an international context
B: US concept of gross income
C: US taxation of business operations
D: US taxation of entity type
Thursday, 4 March
II. US federal income tax: overview (cont.)
E: US corporate income tax
F: Earnings and profits
G: US corporate reorganisations
H: Partnerships
Tuesday, 9 March
III. Inbound investment
A: US sourcing of income and expenses
B: INCO terms
C: US taxation of non-US persons
D: FDAP
E: US trade or business
F: Anti-interest stripping rules
G: Branch profits tax
H: FIRPTA
Thursday, 11 March
III. Inbound investment (cont.)
I: Special US tax treaty issues: Limitation of benefit articles, saving clauses, treaty overrides
IV. Outbound investment
A: Foreign tax credit
Tuesday, 16 March
IV. Outbound investment (cont.)
B: CFC and reporting
C: Subpart F income
D: FDII
E: GILTI
F: Investment in US property
G: Sale of shares in CFC
Thursday, 18 March
V. Other issues
A: Summary/overview of course to date
B: Transfer pricing
C: State and local taxes
D: Transfer taxes
