Distinguish the differences between inbound and outbound transactions. Topics include U.S. shareholder and CFC status; operating rules of subpart F income; foreign tax credit rules; rules covering sourcing, withholding, and compliance issues; and more. Highlights
*Controlled foreign corporations (CFCs)*U.S. shareholders*Subpart F income*E&P*Dividends-received deductions (DRD)*Global intangible low-taxed income (GILTI)*Section 965*Foreign-derived intangible income (FDII)*Base erosion and anti-abuse tax (BEAT)*Previously taxed income (PTI)*Passive foreign investment corporation (PFICs)*Foreign tax credits (FTCs)*Dual-consolidated losses (DCLs)*foreign currency compliance*Effectively connected income (ECI)*Branch profits tax (BPT)*1120-Fs*Foreign Account Tax Compliance Act (FATCA)*Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)