Description

This Certificate course will teach you:

• Build a solid foundation.
• Valuable to anyone who needs to understand the complexities of international taxation, this U.S. International Tax: Core Concepts bundle offers you the opportunity to build a solid foundation in U.S. international taxation.

Course Details:

• This two-course series covers topics such as distinguishing the differences between various types of global tax systems and certain characteristics of each, entity classifications and different forms of operating a business in a foreign country. This series includes:
  • Part 1: International Tax Foundation
  • Part 2: Introduction to U.S. Outbound and Inbound Transactions

Digital badges: Your professional distinction

• After you complete this two-part self-study online series, you will be awarded with a certificate in the form of a digital badge. Proudly display it anywhere on the internet — a personal blog, a social site like LinkedIn, Facebook or Twitter, Open Badges, a bio page on a company website or your email signature.

Key Topics

• Tax Systems
• Inbound/Outbound Taxation
• Residency
• Foreign Tax Credits
• Entity Classification
• Subpart F Income Taxable presence in U.S • Income Sourcing in U.S.
• Withholding taxes in U.S.
• Tax Treaties
• Transfer pricing
• Key Actions under OECD BEPS initiative
• FDII
• GILTI

Learning Outcomes
Part I:

• Distinguish the differences between various types of global tax systems and certain characteristics of each
• Recall entity classification and hybrids
• Recognize the different forms of operating a business in a foreign country
• Recall the concept of a permanent establishment / taxable presence in the United States and globally
• Recall U.S. income sourcing rules
• Identify general U.S. withholding tax rules
• Recognize the general function and benefits of most income tax treaties
• Recall the basics of transfer pricing rules for controlled transactions in the U.S. and globally
• Identify the key actions under the OECD Base erosion and profit shifting (BEPS) initiative

Part 2:

• Identify business transactions that generate outbound tax issues.
• Recognize the approach for taxing U.S. persons with foreign activities.
• Describe the key tax reform provisions affecting outbound transactions.
• Recall the basics of the anti-deferral provisions applicable to controlled foreign corporations.
• Recognize foreign currency issues affecting outbound transactions.
• Recognize reporting requirements applicable to U.S. persons invested in foreign corporations, foreign disregarded entities, and/or foreign partnerships.
• Recall effectively connected income (ECI) to a U.S. trade or business
• Recall the rules for sourcing of income
• Recall the rules for fixed or determinable, annual or periodic gains, profits, and income (FDAP)
• Identify a framework for determining and calculating ECI and the Branch Profits Tax (BPT)
• Indicate a general framework on the U.S. withholding taxes