This program will begin the jurisdictional basis for the assertion of the U.S. taxing jurisdiction over U.S. persons. After a discussion of the foreign tax credit rules and the anti-deferral regimes (Subpart F, GILTI, and PFIC), Mr. Misey will discuss export benefits (IC-DISCs and the FDII deduction).
Learning Objectives
- Identify issues with respect to cross border transactions
- Determine how the U.S. rules eliminate double taxation
- Recognize opportunities for tax minimization strategies
Major Topics
- The U.S. Taxing Jurisdiction
- Sourcing Rules
- Foreign Tax Credits
- Subpart F
- Global-Intangible Low-Taxed Income
- Passive Foreign Investment Companies
- IC-DISCs
