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
include:
- How the American
Jobs Creation Act of 2004 changes 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
Level of knowledge: Basic
Field
of study: Taxation
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