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CPE Self-Study

International Taxation

  • $189.00-$239.00
    International Taxation In Stock Product #: 732012
    AICPA Member: $189.00
    Non-Member: $239.00

In this CPE course, get a solid understanding of international tax terminology and regulations that apply to a U.S. entity involved in global operations, or for a foreign entity doing business in the U.S. Whether your organization is contemplating a global move or is already involved in international business, you need to know about the activities that create multi-jurisdictional tax exposure and the required tax reporting for each relevant jurisdiction.

Key Topics

  • Export income
  • Receipts in foreign currency
  • Allocation and apportionment of deductions
  • U.S. foreign tax credit – fundamentals and special rules
  • Initiation of foreign operations
  • Foreign branches and affiliated companies
  • Sale of use of tangible property
  • Foreign business operations in the United States
  • Foreign business sales of tangible property in the United States
  • Foreign business provision of services in the United States
  • Exploitation of business assets outside of the United States
  • Use of foreign tangible/intangible property in the United States
  • U.S. withholding taxes on foreign businesses

Learning Objectives

This course will prepare you to:

  • Apply basic foreign tax law fundamentals to properly serve clients that require international tax compliance
  • Comply with U.S. tax reporting requirements for inbound and outbound transactions and operations
  • Source income to a foreign jurisdiction
  • Determine the required allocation and apportionment of deductions to foreign sourced income
  • Analyze which foreign taxes are creditable against U.S. taxes
  • Report foreign bank accounts and investments in jurisdictions including FATCA rules
  • Describe the U.S. tax reporting requirements for foreign affiliates
  • Structure transactions and/or business operations of foreign-based service businesses entering the United States
  • Evaluate the effect of treaties on the taxation of your client's foreign based income activities

Prerequisite: Strong knowledge of U.S. Income Taxation

Advance Preparation: None

About the Authors

Adnan Islam JD, MBA, LL.M, CPA

Los Angeles, CA

Adnan Islam is the International Tax Director with McGladrey. He is a licensed international tax attorney and CPA (NY & CA) with a focus on international tax planning, restructuring, technical tax analysis, & global information reporting. Adnan was previously Senior Manager of International Tax Services with Grant Thornton LLP and also EisnerAmper LLP. He has experience working with international tax while at Ernst & Young and PrisewaterhouseCoopers as well.

Mr. Islam has worked primarily with corporate, business owners, and private equity fund clients regarding: subpart F income issues; outbound and inbound transactions; research and analysis on optimal global finance and holding company jurisdictions; tax withholding taxes and income tax Treaty analysis; U.S. real estate dispositions by foreign persons; coordination with foreign partners and Technical Branches of the IRS / Treasury; cross-border reorganizations including mergers, acquisitions, and liquidations; debt vs. equity analysis; permanent establishment and ETB/ECI issues; check-the-box planning; transfer pricing; technical review of Forms 5471, 8858, and 8865; and 9100 (and PLR) relief rulings for IRS submission. Adnan has extensive experience managing international tax analyses with various jurisdictions including: Canada, UK, France, Netherlands, Luxembourg, Belgium, Australia, China, Hong Kong, India, Singapore, Cyprus, Germany, Ireland, and Mexico.

Mr. Islam's areas of concentration are Cross-border Transactions; IP Migration; Tax Treaty analysis; European structuring and holding companies; Private Equity, Alternative Investments, and Asset Managers' international tax issues; Mergers & Acquisitions (tax analysis, due diligence and structuring); subchapter C analysis; analyzing intercompany transactions; Chapter 3 Withholding Tax analysis; tax provision (ASC 740) review; and transfer pricing.

Mr. Islam is involved in leading the International Growth Council (IGC) initiative for Los Angeles and FATCA and withholding tax technical lead for the Western Region; Foreign Account Tax Compliance Act "FATCA" - assessment and advice under Chapter 4 of the Internal Revenue Code. Adnan is a licensed attorney admitted to practice law in New Jersey, DC, and California and a Certified Public Accountant (CA & NY). He holds a Juris Doctor (J.D.) and an M.B.A. from Rutgers University; and an LL.M. in Taxation from the New York University School of Law. He has previously worked within the International Tax Services and M&A tax groups at other Big 6 Firms.

Mr. Islam is involved in leading the International Growth Council (IGC) initiative for Los Angeles and FATCA and withholding tax technical lead for the Western Region; Foreign Account Tax Compliance Act "FATCA" - assessment and advice under Chapter 4 of the Internal Revenue Code. Adnan is a licensed attorney admitted to practice law in New Jersey, DC, and California and a Certified Public Accountant (CA & NY). He holds a Juris Doctor (J.D.) and an M.B.A. from Rutgers University; and an LL.M. in Taxation from the New York University School of Law. He has previously worked within the International Tax Services and M&A tax groups at other Big 6 Firms.



About the Publisher

AICPA

About the AICPA The American Institute of CPAs is the world’s largest member association representing the accounting profession, with more than 412,000 members in 144 countries, and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education and consulting. The AICPA sets ethical standards for the profession and U.S. auditing standards for private companies, nonprofit organizations, federal, state and local governments. It develops and grades the Uniform CPA Examination, and offers specialty credentials for CPAs who concentrate on personal financial planning; forensic accounting; business valuation; and information management and technology assurance. Through a joint venture with the Chartered Institute of Management Accountants, it has established the Chartered Global Management Accountant designation, which sets a new standard for global recognition of management accounting.