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CPE Self-Study

International Taxation - Tax Staff Essentials

  • $139.00-$179.00
    International Taxation - Tax Staff Essentials Availability : Online Access Product #: 157825
    AICPA Member: $139.00
    Non-Member: $179.00
  • Contact Sales
    Contact a representative for group pricing or on-site training opportunities. 800.634.6780 (Option 1) | Contact Us Product #: GT-TSE.INT

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. This course has been updated for Tax Reform and the impact of the Tax Cuts and Jobs Act of 2017.

Learning Objectives

  • Understand how to comply with U.S. tax reporting requirements for inbound and outbound transactions and operations.
  • Learn how income is "sourcedâ€? to a foreign jurisdiction.
  • Determine the required allocation and apportionment of deductions to foreign sourced income.
  • Analyze which foreign taxes are creditable to the U.S. tax bill.
  • Describe the U.S. tax reporting requirements for foreign affiliates.
  • Develop an awareness of alternative organizational structures for international operations.
  • Identify how to structure transactions and/or business operations of foreign-based service businesses entering the United States.
  • Recognize the effect of treaties on the taxation of foreign-based income activities. Recognize the updates to international taxation as a result of the Tax Cuts and Jobs Act of 2017.

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
  • FDII
  • GILTI

Who Will Benefit

CPA firm seniors (and above) and other tax professionals looking for the best techniques to understand international taxation.

Discounts

Tax Section Members Receive Additional Savings!

When you log into this website with your AICPA member user account, the section/credential discount will be automatically applied during checkout. Should you have any questions or encounter any issues, please contact the AICPA Service Center at 888-777-7077 or service@aicpa.org.

Find out more information on the Tax Section.

System Requirements

About the Authors

Adnan Islam JD, MBA, LL.M, CPA

Los Angeles, CA

Adnan Islam is an International Tax Director with RSM US LLP, Los Angeles Office. 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

American Institute of CPAs

The American Institute of CPAs (AICPA) is the world’s largest member association representing the CPA profession, with more than 418,000 members in 143 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 specialized credentials for qualified professionals who concentrate on personal financial planning; forensic accounting; business valuation; and information management and technology assurance. With The Chartered Institute of Management Accountants (CIMA), it offers the Chartered Global Management Accountant (CGMA) designation, which sets the global benchmark for quality and recognition in management accounting.

The AICPA and CIMA also make up the Association of International Certified Professional Accountants (the Association), which represents public and management accounting globally, advocating on behalf the public interest and advancing the quality, competency and employability of CPAs, CGMAs and other accounting and finance professionals worldwide.

The AICPA maintains offices in New York, Washington, DC, Durham, NC, and Ewing, NJ.