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In a global business environment, transactions with customers and suppliers often transcend national borders, and investment and activities are frequently cross-border as well. An understanding of the U.S. international tax rules, especially after enactment of the 2017 Tax Act, is of paramount importance to a wide variety of tax and corporate professionals.
This year’s program will be led by international tax experts and focuses on specific types of outbound and inbound investment and activities, and their U.S. tax consequences. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the new U.S. tax rules address these issues. Special attention will be given to the ways the U.S. tax rules impact financings, mergers, acquisitions, and other commercial activities.
What You Will Learn
After completing this program, participants will be able to:
- Distinguish between situations where a U.S. investor should structure a foreign corporation to operate directly, and those where they should form a separate entity, under the changes made by the 2017 Tax Act
- Identify the types of expenses that can be allocated to gross income
- Apply foreign tax credit baskets to the foreign income of U.S. shareholders in a controlled foreign corporation (“CFC”)
- Recognize the impact of the sale of CFC stock on the repatriation of earnings of a foreign corporation
- Identify foreign corporations whose U.S. owners are not subject to U.S. tax until a dividend