U.S. International Tax: Advanced Issues

Exploring advanced international tax topics

The U.S. International Tax: Advanced Issues bundle dives into how to handle complex tax issues such as transfer pricing, tax treaties, and corporate formations.

This series of five courses includes:

• U.S. Transfer Pricing and Global BEPS
• U.S. Tax Treaties
• Corporate Formations, Reorganizations, Acquisitions, and Liquidations
• International Tax Transactions I
• International Tax Transactions II

An approachable discussion of complex topics

Designed with realistic, illustrative examples and exercises, courses in this series help you understand the often-complex intricacies of special areas of international taxation, including U.S. tax treaties and corporate reorganizations. Expert instructors translate the Internal Revenue Code and regulations in an easy-to-understand way, drawing on their practical experience.

Updated for final regulations, OECD initiatives

This series has been updated to cover recent issuances of final regulations and initiatives by the Organisation for Economic Co-operation and Development (OECD).

Part of a comprehensive international tax education

This self-study online course is part of the [U.S. International Tax Certificate] (https://www.aicpa-cima.com/cpe-learning/course/us-international-tax-certificate), a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation. Developed in partnership with Grant Thornton, this certificate program is valuable to anyone who needs to understand the complexities of international taxation.

Courses in this series may be purchased individually. However, 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

• Transfer pricing methods
• Permanent establishment
• Formations
• Reorganizations
• Liquidations
• Inversion rules under Section 7874
• Related party stock sales
• Non-recognition transactions

Learning Outcomes

• Identify the accepted transfer pricing methods and recognize when each is appropriate to use.
• Recognize the base erosion and profit shifting (BEPS) initiatives and their relationship to U.S. and global transfer pricing.
• Identify when a PE exists.
• Identify the tax consequences of an exit event, such as liquidation, related-party sale, and third-party sale (with availability of certain elections).
• Recognize the implications of making a Section 338 election in an acquisition of foreign corporate stock from a third party.
• Recognize whether an outbound liquidation qualifies for non-recognition treatment under IRC Section 332.
• Identify when IRC Section 367 alters the application of the general non-recognition tax rules of IRC Sections 351 and 332.