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Credits: 2

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  • This course was excellent and Michael Tucker does a great job of asking the questions we are all thinking.

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Tax Rules Specific to Businesses that Expand Beyond the U.S. (BOUS)

  • Customer Rating
    Not Yet Rated
  • Field of Study
    Taxes
  • Level
    Intermediate
  • Credits
    2
  • Qualifies for

    IRS CPE

Overview

Tax practitioners are often asked by their U.S.-based business clients that are considering conducting business outside the U.S. to advise them with respect to the tax consequences of such an expansion. The U.S. tax rules in this area are highly complex, and to some extent interact with the tax rules of the country to which the business is expanding and any applicable tax treaties. This program is a general overview of the tax rules that apply when U.S. businesses expand outside the U.S.

Major Topics:

  • Choice of entity – structuring foreign operations
  • Permanent Establishment
  • Controlled Foreign Corporations and Subpart F
  • Foreign tax credits – direct and indirect credits
  • Source of Income Rules
  • Overview of U.S. reporting for international operations

Learning Objectives

  • Prepare U.S. tax practitioners to advise their clients who are considering expanding outside the United States regarding the domestic tax consequences of such an expansion

Who should take this course:

Designed for:

Tax practitioners advising United States businesses regarding the United States tax consequences of expanding outside the United States

Prerequisite:

Basic understanding of individual taxation

Advanced Preparation:

None

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