Introduction to U.S. Outbound and Inbound Transactions

Overview

Gain 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: Core Concepts bundle. You must purchase the bundle to earn the digital badge.

This course provides a solid foundation of U.S. inbound and outbound taxation and key concepts that are related. It begins with the business transactions that generate outbound tax issues in the U.S. tax system, such as the introduction to the one-time transition tax introduced by the Tax Cuts and Jobs Act of 2017. Also considered are:

• Concepts related to global intangible low-taxed income, foreign tax credits, foreign currency, and foreign-derived intangible income;
• Inbound taxation topics like calculating effectively connected income, sourcing income, the branch profits tax, the Foreign Investment in Real Property Tax Act;
• How to interpret tax treaties and how they can reduce U.S. income and withholding taxes; and,
• The Base Erosion Anti-Abuse Tax created by the Tax Cuts and Jobs Act

Highlights

Key Topics

• One-time transition Tax
• GILTI
• Dividends Received Deduction
• Foreign-Derived Intangible Income
• Foreign Currency
• Entity Classification options
• Effectively Connected Income
• Branch Profits Tax
• Withholding Taxes
• Foreign Account Tax Compliance
• Foreign Investment in Real Property Tax
• Tax Treaties
• Base Erosion Anti-Abuse Tax

Prerequisites

None

Designed For

Who Will Benefit

• Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.

Objectives

Learning Outcomes

• 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