
Taxation of Income Earned by Foreign Subsidiaries
Covering the definition of a U.S. shareholder and controlled foreign corporation (CFC) status in the context of international taxation.
Format
Online
NASBA Field of Study
Taxes
Level
Intermediate
CPE Credits
7
Author(s)
Eric Gabbai, Kyle Brandon, Christopher Summer, Farid Khosravi, David Zaiken
Availability
1 year
Product Number
ITCC25SSO
Decoding international tax acronyms: CFCs, PFICs, and more
As your business clients expand internationally, it’s essential that you stay up to date on the latest U.S. income taxation rules for foreign subsidiaries. In particular, the following topics are discussed:
- Controlled foreign corporation (CFC) status
- The definition of a U.S. shareholder for CFC purposes
- Subpart F income
- Earnings and profits (E&P)
- Passive foreign investment companies (PFICs)
- Foreign asset reporting for U.S. federal income tax purposes
With practical examples and detailed discussions of the many applications of these concepts, learners gain a comprehensive understanding of the taxation of income earned by foreign subsidiaries.
Part of a comprehensive international tax education
This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation.
This course can be purchased individually or as part of the U.S. International Tax: Inbound and Outbound Transactions bundle. You must purchase the bundle to earn the digital badge.
Who Will Benefit
Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.
Key Topics
- U.S. outbound transactions
- Subpart F income
- Earnings and profits in an international context
- Passive Foreign Investment Companies and foreign assets
Learning Outcomes
- Identify a controlled foreign corporation (CFC) and a U.S. shareholder.
- Identify the mechanics of Section 962 elections.
- Differentiate among Subpart F income types.
- Identify situations that create Subpart F income for a U.S. entity.
- Identify common E&P adjustments.
- Apply E&P concepts to common international tax transactions.
- Determine the consequences of PFIC ownership.
- Identify PFIC reporting requirements and foreign asset reporting requirements beyond PFICs.
Group ordering for your team
2 to 5 registrants
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Start order6+ registrants
We can help with group discounts. Email client.support@aicpa-cima.com
US customers call 1-800-634-6780 (option 1)
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