Taxation of Income Earned by Foreign Subsidiaries

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  • Location
    • Your Space
      Your Space
      Self Study - AICPA, ID 00000
  • Credits
    • 7.00
  • Credit Type(s)
    • Taxes (Technical) (7.00)
  • Prerequisites
    • None

  • Vendor
    • AICPA
  • Level
    • Basic
  • Fields of Study
    • Taxes
  • Message
    • When & Where You Want

Description

This CPE self-study course focuses on determining US shareholder and CFC status under the new rules from tax reform.

Objectives

  • Identify a CFC and a U.S. shareholder
  • Apply constructive stock attribution rules properly (
    • Tax reform)
    • Distinguish how rules around indirect and direct ownership is applied
    • Section 962 Elections
    • Differentiate the different types of subpart F income
    • Identify situations that would create subpart F income for a U.S. entity
    • Calculate subpart F income for specific scenarios
    • Apply specific rules providing exceptions and limitations for subpart F income
    • Identify the importance of E&P in an International Context
    • Recall E&P
    • Calculate Common E&P Adjustments
    • Apply E&P Concepts to common International Tax transactions
    • Determine when you have PFICs
    • Recognize the consequences of PFIC ownership
    • Differentiate the tax implications of PFIC elections
    • Recall PFIC reporting
    • Recognize Foreign Asset reporting requirements beyond PFIC

Highlights

  • Determination of CFC and U.S. Shareholders
  • Application of constructive ownership rules
  • New downward attribution
  • Section 962
  • All forms of subpart F income (FPHCI, sales, and services)
  • Operating rules
  • Exceptions
  • Why is E&P Important
  • Overview of the E&P Computation
  • Common E&P Adjustments
  • Applying E&P to Your Clients: What to look for and real-world examples
  • Reporting E&P on Form 5471
  • Tax issues resulting from E&P issues
  • Definition of a PFIC and Examples
  • Shareholder Taxation of PFICs without QEFs
  • Shareholder Taxation of PFICs with QEFs
  • Mark-to-market Elections (Mark-to-market 1296)
  • Retroactive Relief
  • Foreign Asset Reporting Requirements
  • Excess Distribution 1291
  • Qualified Electing Funds 1293 & 1295
  • FBARs and 8938s

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