THREE DAY IN-PERSON COURSE
Introduction to
United States International Corporate Tax
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US International Corporate Tax
What does it cover?
A comprehensive overview of US international tax, focusing on inbound and outbound investment by corporations.
Who should attend?
This course is ideal for tax advisers new to US international tax, working in/with US multinationals or dealing with US tax less frequently.
Why choose this course?
Course numbers are limited to 20 making it highly interactive, plus the short three-day duration means it is ideal for busy tax professionals and/or those travelling from outside the UK.
What's included in the fee?
The fee includes tuition, including many worked examples, full course documentation and access to a trial of selected online materials, plus refreshments.
Overview of the Course Agenda
Structure of the US Tax System
- Federal taxation versus state and local taxation
- The federal tax system: the Internal Revenue Code
US Federal Income Tax
- Taxation of worldwide income of US persons
- Individuals, corporations, partnerships, trusts and estates
- Classification of business entities: the “check the box” regime
- Taxation of non-US persons
- Source of income
Inbound Investment
- Non-US persons engaged in the conduct of a US trade or business
- Non-US persons not engaged in the conduct of a US trade or business
- Special US tax treaty issues: Limitation of benefit articles, saving clauses, treaty overrides
- Specific anti-avoidance rules: interest-stripping and anti-conduit regulation
Outbound Investment
- Foreign tax credit
- Subpart F income
- Global Intangible Low-Taxed Income (GILTI)
- Investment in US property
- Sale of CFC shares
Other International Issues
- Transfer pricing rules: Code section 482 and regulations
- Anti-avoidance: general case law doctrines and main statutory provisions
- Indirect Taxes: customs duties; state and local sales taxes
Video Conferencing
Please get in touch with your questions on the Introduction to US Corporate International Tax course
Thank you!
