U.S. Taxation of International Transactions

This course analyzes the tax treatment, issues, planning techniques and underlying government policies involved in doing business internationally. The course incorporates concepts learned in all of the tax courses as they relate to the impact on cross-border outbound transactions (i.e., the taxation of US taxpayers doing business abroad). Topics include the source of income, transfer pricing, controlled foreign corporations (CFCs), Subpart F income, foreign tax credits, Global Intangible Low-Tax

• Explain how countries mitigate the impact of double taxation
• Apply sourcing rules for various income types
• Analyze incentives for generating certain types of foreign income
• Calculate the Foreign Tax Credit to offset U.S. tax on foreign income