THREE DAY IN-PERSON COURSE

Introduction to United States International Corporate Tax

Build a working knowledge of US international corporate tax in three days, taught by international tax advisor and lecturer Narelle MacKenzie.



Upcoming dates:

London | 24th - 26th November 2026
Dublin | Late May 2027

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.

US International Corporate Tax

What does it cover?

A comprehensive overview of the US tax rules affecting multinational groups, from the federal corporate tax system to how the US taxes cross-border investment.

Who should attend?

Tax professionals who are new to US international tax, perhaps working in a group with a US parent or US operations, or advising clients who deal with the US.

Why choose this course?

Places are limited to 20, so you can ask questions and discuss the issues you meet in your own role. Three days in person suits busy professionals, including those travelling to the venue.

What's included in the fee?

Tuition built around worked examples, full course documentation and a trial of selected online materials, with refreshments and lunch across the three days.
The course was extremely informative and covered a wide range of areas on US taxation. It was very useful for me personally and a great insight to all things US tax.

Senior Tax Manager, Professional Services, UK

Narelle tailored the course content based on the most relevant areas for our roles to ensure that everyone was meeting their individual learning objectives for the course.

Group Tax Manager, UK

What you'll gain from the course

Speak the language

Sometimes it seems like US colleagues and advisers are speaking a foreign language, full of terms like Subpart F, E&P and FDAP. Narelle breaks down the jargon with plenty of worked examples, so you can join US tax conversations with confidence.

Get more from your US advisers

Three days won't turn you into a US tax specialist, and the course doesn't pretend it will. It gives you the grounding to brief your advisers clearly, ask sharper questions, and judge when you need specialist advice.

Spot the issues early

By increasing your knowledge of how the US tax system operates, you can spot potential issues early. In a US-headed group, you'll understand what your US colleagues are dealing with, making you a more effective tax adviser in your own region. In a group with US operations, you'll know the US questions to ask before decisions are made, avoiding costly mistakes and recognising planning opportunities.

Learn alongside your peers

Participants have ranged from tax managers to tax directors, working in US-parented groups, UK and Irish headed multinationals with US operations, professional services firms, a pension fund and tax authorities. Some tax teams book together, with colleagues attending from across Europe. With numbers capped at 20 and three days in person, there is time to share experiences and compare approaches with people dealing with the same questions.

How you will learn

Narelle teaches around a table, not from a lecture podium. At the start of the course, she asks each participant what they want from the three days. She then tailors the content to focus on the most relevant areas for your role, so everyone meets their individual learning objectives.

The sessions themselves combine worked exercises, discussion and the experience Narelle brings to every topic. Comprehensive slides accompany the course, giving you reference materials you will return to long after the three days end.

Taught by Narelle MacKenzie, lecturer at San Diego State University

Narelle MacKenzie is a well-known international tax advisor based in San Diego, with over 30 years of experience in international tax. Her career spans public accounting and industry, including seven years as an International Tax Director with PwC and Tax Director at Goodrich Corporation (a Fortune 500 company). She now runs her own international tax consulting practice, advising accountants, attorneys and in-house tax departments on cross-border planning and compliance.

Narelle began her career in Australian tax, first encountering the US system while working in-house for a multinational group. She then moved to California, and has worked in US international tax for nearly three decades. Her experience covers cross-border work in more than 20 countries, including supply chain projects, new manufacturing facilities and secondment arrangements. Having sat on both sides of those conversations, she knows what US tax teams need from their advisers or colleagues elsewhere, and what they need to understand in return.

Narelle has lectured at San Diego State University since 2007, teaching graduate classes in US international tax and multi-jurisdictional tax. She is an award-winning speaker, a Past President of the San Diego chapter of CalCPA, and holds CPA qualifications in both Australia and California alongside the IRS Enrolled Agent credential.
Narelle MacKenzie, Lecturer, San Diego State University
"This course is very close to my heart. I feel very passionate about US international tax and ensuring that others enjoy learning the material.

We start with the basics of the US tax system, because the international rules are an overlay on top. Then we cover the inbound rules, which are becoming more and more relevant with the One Big Beautiful Bill Act and its incentives to manufacture and operate in the United States. On the third day, we cover outbound taxation for US multinationals investing overseas.

If you're advising on investment into the US, this course is great for identifying issues that may impact your business or your clients. And if you work for a US multinational, you'll understand why your US colleagues ask the questions they do, and be able to help with what they need."

Narelle MacKenzie

Overview of the Course Agenda

Day 1: Structure of the US Tax System and Federal Overview

MORNING
I. The structure of the US tax system and federal overview

A: US taxation in an international context
B: US concept of gross income
C: US taxation of business operations
D: US taxation of entity type
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AFTERNOON
II. US federal income tax: overview (continued)

E: US corporate income tax
F: Earnings and Profits
G: US corporate reorganizations
H: Partnerships
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Day 2: Inbound Investment

MORNING
III. Inbound Investment

A: US sourcing of income and expenses
B: Incoterms
C: US taxation of non-US persons
D: FDAP
E: US trade or business
F: Anti-interest stripping rules
G: Branch profits tax
H: FIRPTA
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AFTERNOON
III. Inbound Investment (continued)

I: Special US tax treaty issues: Limitation of benefit articles, saving clauses, treaty overrides

Day 3: Outbound Investment and Other Issues

MORNING
IV. Outbound Investment

A: Foreign Tax Credit
B: Subpart F income
C: Net CFC Tested Income
D: Investment in US property
E: Sale of CFC shares
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AFTERNOON
IV. Other Issues

A: Summary/overview of course to date
B: Transfer pricing
C: State and local taxes
D: Transfer taxes

Book Now 

Book your place on the Introduction to US International Corporate Tax course:

Venue: Central London (TBC)
Date: 24th to 26th November 2026


The fee for this three-day course is £1,845 + 20% VAT. 

Book today at the early bird rate of £1,645 + 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. Alternatively, contact us at info@extrataxtraining.com.

Book Now (ROI - Hidden)

Book your place on the Introduction to US International Corporate Tax course:
  • Location: Griffith College, Dublin 8
  • Date: 19th - 21st May 2026
  • Standard Fee: €2,095

Book today at the early bird rate of €1,895
Early bird rate ending Friday 24th April
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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. Alternatively, please contact us at info@extrataxtraining.com.

Course information

What are the course timings each day?

The Introduction to US International Corporate Tax course runs across three full days, with a comprehensive agenda to cover. On day one, arrive from 9am for a 9.30am start, finishing at 5pm. Days two and three run from 9am to 5pm. Each day breaks for lunch, which is provided, with tea and coffee breaks through the morning and afternoon.

Where is the course held?

The venue for each course is finalised closer to the date. Previous London courses have been held at &Meetings near Aldgate, and previous Dublin courses in the city centre. Confirmed venue details are included in your joining instructions.

What happens after I book?

Once you book, you'll receive access to the course area on our learning platform, where your joining instructions and course materials will be shared. About a week before the course, we will be in touch to arrange your lunch order and check any dietary requirements. If you have questions at any stage, the ExtraTax Training team is a phone call or email away.

Can I claim CPD for the course?

The Introduction to US International Corporate Tax course provides around 6.5 hours of structured learning each day. ExtraTax Training provides a certificate of attendance, which you can use to record CPD in line with your professional body's requirements.
Narelle was great and covered a lot of material in a short space of time. I have gone away with things that can be put into practice from day one. I would recommend this course to anyone looking to enhance their US tax knowledge.

Group Tax Manager, UK

A helpful walk through key US tax principles that has given me a good grounding in US tax from which to discuss issues with US tax advisers and colleagues, and to do my own research or read in to specific US tax questions.

Senior Investment Tax Manager, UK

Bespoke US tax training for your team

ExtraTax Training works in collaboration with Narelle MacKenzie to offer bespoke US tax training. If your firm, in-house team or organisation would like a tailored version of this course, focusing on the issues most relevant to your work, we can arrange a dedicated delivery.

Narelle also offers other courses, including a one-day US tax update for those who know the fundamentals and want to bring their knowledge up to date. Bespoke training can be delivered in person or online. To start the conversation, contact us at info@extrataxtraining.com or use the form below.
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Register your interest for the next course in Dublin

The Introduction to US International Corporate Tax course returns to Dublin in late May 2027, with exact dates confirmed in late 2026. Register your interest below and we will contact you as soon as booking opens.

Frequently asked questions

Do I need any US tax knowledge before attending?

No. The Introduction to US International Corporate Tax course assumes no prior knowledge of US tax. The course begins with the structure of the US tax system and the federal corporate tax rules, before moving on to the international rules that build on them. Participants who already have some US tax knowledge also attend, to fill gaps and put structure around what they have picked up in their roles.

Can I attend the course online?

No, the Introduction to US International Corporate Tax course is an in-person course, held in London, United Kingdom and Dublin, Ireland. The teaching is built around discussion and worked exercises in a small group, which is what makes the course work, so there is no online or hybrid option. If your team would prefer online delivery, please contact us to discuss bespoke US tax training with Narelle MacKenzie.

Can I attend for one or two days rather than all three?

The Introduction to US International Corporate Tax course is designed as a complete three-day programme. Each day builds on the last, so attending in full is how you get the value from it. Bookings are for the full course. If three consecutive days are difficult in the current dates, the course runs each year in London and Dublin, and a later sitting may suit you better.

Is this course preparation for the ADIT US Tax exam?

The Introduction to US International Corporate Tax course is a practical three-day course, using real-world scenarios to show how the US tax rules apply in practice. There is overlap between the topics covered and the ADIT Module 2.10 syllabus, but it is not an exam preparation course. If you are looking to study US tax for the ADIT qualification, ExtraTax Training offers a dedicated online course for the ADIT US Tax module.

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

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