Taxation of US Person’s Foreign Activities(Individuals or US entities)
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Foreign Tax Credits
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Subpart F inclusions
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Passive Foreign Investment Companies
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High Tax Exemption vs Participation Exemption
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Source of income rules guidance
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Planning for foreign operations
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Determinants of foreign country taxation
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Structuring the foreign operation
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Operations in high-tax foreign countries
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Operations inlow-taxforeigncountries
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Common Issues to Outbound and Inbound activities
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Transfer pricing
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Income tax treaties
Taxation of Foreign Person’s US Activities:Foreign Persons investing in the U.S. (FDAP income)
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Overview of U.S. system for taxing foreign persons
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Withholding on the income of foreign persons in the U.S.
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Procedures on the FATCA and FDAP regimes
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Taxation and withholding on the sale of U.S. real property- FIRPTA
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Definition and applicability of US tax residentrules
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Source of income rules guidance
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Tax treaties and limitations on benefits
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Sec. 367 – Outbound, Inbound, and Foreign-to-Foreign Transfers of Property
Taxation of Foreign Person’s US Activities:Foreign Persons doing business in the US (ECI Income)
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Overview of U.S. system for taxing foreign persons
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Withholding on the income of foreign persons in the U.S.
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Definition and applicability of US taxresidentrules
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Source of income rules guidance
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Taxation of effectively connected income with U.S. trade or business
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Branch taxes (applies toforeigncorporations only)
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Anti-earnings stripping provisions
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Tax treaties and limitations on benefits
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Sec. 367 – Outbound, Inbound, and Foreign-to-Foreign Transfers of Property
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