Course ID: TOMNT

Taxation of Multinational Transactions

This course provides answers to two questions related to the taxation of multinational transactions:

• Which taxpayers are subject to the United States tax law?
• What income is subject to taxation under the United States tax laws?

We review both outbound transactions (foreign activities by a United States taxpayer) and inbound transactions (activities in the United States conducted by a non-U.S. taxpayer).

In-person and live webcast CPE credit: 4.0

Learning Objectives

After completing this course, you will be able to:

Contrast U.S. taxpayers and foreign taxpayers.
Assess the sourcing of income and the foreign tax credit.
Assess how U.S. taxpayers are taxed on outbound investments in foreign corporations.
Formulate the U.S. income tax on foreign persons.

Major Topics

U.S.-source and foreign-source income
Controlled foreign corporations
Subpart F income
Global Intangible Low-Tax Income (GILTI)
Effectively connected income

Advanced Preparations

None

Who Should Attend

Senior staff, managers, and partners

Fields of Study

Taxes

Prerequisites

Fundamentals of corporate taxation

Provider

Business Learning Institute

CPE Credits

4.0

Level

Advanced

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