U.S. Taxation of Foreign Corporations: A Case Study Approach

Description

This course is a case study designed to provide a comprehensive overview of U.S. taxation of a foreign corporation. Using a specific example, the course will walk through step-by-step mechanics on how to calculate the income inclusions and foreign tax credits under tested income (formerly known as global intangible low-taxed income or GILTI), Subpart F, and passive foreign investment company (PFIC) regimes. These computations have been updated to reflect changes enacted by the One Big Beautiful Bill Act (OBBBA). The case study will further evaluate the tax impact of subsequent distributions from the foreign corporation and sales of its stock. A compare-and-contrast approach will highlight the different outcomes of these regimes for individuals and for C corporations, empowering participants to advise their clients on the most tax-efficient way to structure their foreign investments.

Objective

Explain the similarities and differences between tested income, Subpart F, and PFIC regimes Understand the mechanics of income inclusions and foreign tax credits available under tested income, Subpart F, and PFIC regimes Compare and contrast the overall tax liability under different circumstances Identify tax-planning opportunities for income from foreign corporations

Credit Types

CPE – Taxes