Foreign Losses, Foreign Currency and Compliance
Valid for one year from purchase date
Self-study - On-Demand
4.5 CPE (4.5 technical)
Course code: 26SI-0155
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This updated course, reflecting changes under H.R. 1, P.L. 119-21 (the One Big Beautiful Bill Act or OBBBA), provides a comprehensive overview of U.S. international tax issues, including dual consolidated loss (DCL) rules, foreign currency regimes, and compliance requirements for outbound transactions. Participants will examine the computation of DCLs, recapture triggering events, and reporting obligations, as well as the interaction of these rules with OECD Pillar 2 and the broader BEPS framework. The course also covers foreign currency concepts such as qualified business units, functional currency determinations, and Section 987 branch and disregarded entity transactions, along with required federal reporting forms and penalties for noncompliance.
Major subjects
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Calculation of dual consolidated losses (DCLs).
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DCL recapture triggering events.
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Foreign currency transaction rules.
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Qualified business units.
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International tax reporting requirements.
Learning objectives
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Recall the purpose of dual consolidated loss (DCL) rules.
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Recognize triggering events that give rise to a DCL recapture.
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Recognize DCL reporting requirements.
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Analyze the interaction of foreign currency transaction rules.
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Identify a qualified business unit (QBU) under Section 989.
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Determine functional currency for foreign entities under Section 985.
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Recognize the complexities of branch and disregarded entity (DRE) currency transactions under Section 987.
Who should take this program?
- Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.
Pricing
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Standard Member Fee |
$109.00
|
 Standard Nonmember Fee |
$135.00
|
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