THREE DAY IN-PERSON COURSE
Introduction to
United States International Corporate Tax
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A word from our guest lecturer
US Tax with Narelle MacKenzie
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.
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.
“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.”
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
Day 1: Structure of the US Tax System and Federal Overview
- Setting the scene
- Gross income – US concept
- US taxation of business operations
- US taxation of entity type
- US corporate income tax
- Earnings and Profits
- US corporate reorganizations
- Partnerships
- Who is a US Person?
Day 2: Inbound Investment
Sourcing of income and expenses, including Incoterms
US Taxation of Non-US persons
US Taxation of Non-US persons
- Fixed, Determinable, Annual, Periodical (FDAP) Income
- US trade or business
- Thin capitalization rules
- Branch profits tax
- Foreign Investment In Real Property Tax Act (FIRPTA)
- Sale of US Partnership Interest
- US tax treaty overrides
Day 3: Outbound Investment and Other Issues
Foreign tax credit
Subpart F income
Investment in US property
Sale of CFC shares
Transfer pricing
State and local taxes
Transfer taxes
- 960 Indirect foreign tax credits
- FTC limitation
Subpart F income
Investment in US property
Sale of CFC shares
Transfer pricing
State and local taxes
Transfer taxes
Video Conferencing
Book Now
Book your place on the Introduction to US International Corporate Tax course:
Dublin | 27th-29th May 2025
The course fee for this three-day workshop is £1,775 plus 20% VAT.
Dublin | 27th-29th May 2025
The course fee for this three-day workshop is £1,775 plus 20% VAT.
If you would like to book for multiple participants or request payment by invoice, please complete the booking request form below.
Register your interest in joining the Introduction to US International Corporate Tax course in Dublin in late May 2025.
Please get in touch with your questions on the Introduction to US Corporate International Tax course
Thank you!
