Self-Study

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

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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.

Major subjects

• Understand how to approach and analyze the U.S. taxation of foreign corporations.
• Using an example, calculate tested income, Subpart F, and PFIC income inclusions for an individual and C Corporation.
• Determine how much foreign tax credit can be claimed against such income inclusions.
• Determine how subsequent dividend distributions from the foreign corporation are taxed.
• Calculate capital gain on the disposition of the foreign corporation.
• Compare different outcomes and discuss the impact of Section 962 election.
• Identify basic strategies for managing tax liabilities related to foreign corporations.

Learning objectives

• 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.

Who should take this program?

• Any tax practitioner with clients invested in a foreign corporation.

Pricing

Our records indicate you are a nonmember. If you register, you will be charged $54.00 (Standard Nonmember Fee). Members: Please log in to receive member fee.

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