Introduction to United States International Corporate Tax

Upcoming dates:
London - 25th - 27th November 2024
Dublin - Late May 2025
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A word from our guest lecturer

US Tax with Narelle McKenzie

Watch this short video to hear directly from Narelle what you can expect from the course.
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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.

Hosted by Narelle MacKenzie, San Diego State University Lecturer

Our host for the three day workshop will be Narelle MacKenzie, a well-known international tax advisor with over thirty years experience working in international taxes, having spent most of her career working with, or for, multinational companies such as United Technologies, PwC, and Toyota Australia.

Narelle is a highly sought-after speaker, course instructor 
and guest lecturer. She has presented at many diverse conferences, including for the California Society of CPAs and the American Bar Association.

Recent speaking engagements covered potential tax issues for US businesses expanding overseas, the impact of the Report of Foreign Bank and Financial Accounts (FBAR) rules, the corporate tax considerations of expats and inpats, and an explanation of the US tax laws for multinationals.
Guest Lecturer
“I have taught this course in London many times and am delighted to partner with ExtraTax Training to bring this much-needed US tax programme back to the UK.

It offers great value for money, with a past participant telling me that he saved the course fee several times over using something he learned in the first hour of this course. Others have mentioned the benefit of demystifying US tax terminology, gaining the ability to discuss their US tax challenges, and identifying potential future or current issues for their organisation or their clients.”

Narelle MacKenzie

International Tax Advisor & Lecturer

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

Book Now

The standard course fee for this three-day workshop is £1,775 plus 20% VAT. 

Book today at the early bird rate of £1,550 plus 20% VAT.
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If you would like to book for multiple participants or request payment by invoice, please complete the booking request form below.

Please get in touch with your questions on the Introduction to US Corporate International Tax course

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