ITCO
INTERNATIONAL TAX ISSUES FOR SMALL AND MEDIUM-SIZED BUSINESSES -- GOING OVERSEAS AND COMING TO THE UNITED STATES

Nonpublicly traded companies are becoming much more involved in international transactions due to Internet sales and increasingly liberal trade policies. The purpose of this course is to focus on the major tax issues affecting nonpublic companies doing business overseas.

Major Topics:

  • Developments in international business transactions
  • Setting up a foreign partnership or alliance
  • Understanding what to do following the repeal of Foreign Sales Corporation (FSC) and the WTO rejection of extraterritorial income exclusion
  • The U.S. company going overseas and the issues of double taxation and foreign tax credit
  • Issues in setting up a foreign subsidiary-insulation from liability, making transfers of property, contributions, sales and royalties
  • Foreign tax credit -- getting easier?
  • Intercompany transfer pricing -- Financial analysis and §482 allocations
  • Foreign corporations doing business in the United States: sourcing rule for FDAP and effectively connected income

Learning Objectives:

  • Understand when items of income are U.S. sourced income and when they are not and understand how and when foreign subsidiaries, including PFICs and QEFs are subject to U.S. taxation
  • Understand how income can be reallocated between U.S. corporations and their subsidiaries
  • Understand how the foreign tax deduction/credit applies to U.S. corporations

Designed For: CPAs who advise U.S. clients with foreign investments and foreign clients with U.S. investments
Level of Knowledge: Basic
Prerequisite: None
Advanced Preparation: None
Credits: 8