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CPE Self-Study

Tax Reform's Impact on International Business

  • $89.00-$109.00
    Tax Reform's Impact on International Business Availability : Online Access Product #: 166360
    AICPA Member: $89.00
    Non-Member: $109.00
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    Contact a representative for group pricing. 800.634.6780 (Option 1) | Contact Us Product #: GT-CL4TRINTL

The monumental passing of the Tax Cuts and Jobs Act results in a significant impact to international business and the global economy. This CPE course provides a comprehensive overview of the changes and guidance on how businesses can identify opportunities and reduce their tax risks with international tax strategies.

Learning Objectives

When you complete this course, you will be able to:

  • Identify changes impacting international tax provisions
  • Identify planning considerations for U.S. multinationals and foreign corporations doing business in the U.S.
  • Identify ways to advise clients on the impact of tax reform changes
  • Recognize new tax planning strategies post tax reform

Key Topics

  • Overview of International Tax Reform
  • Overview of Business Provision (Non-international)
    • Rate Cut
    • Cost Recovery
    • Section 163(j)
    • Modification of NOL Rules
    • Carried Interest
    • Sale/Exchanges of Partnership Interests
  • The International Provisions
    • Quasi-Territorial
      • Dividends Received Deduction
      • Sales/Transfers of 10% owned foreign corporations
      • Foreign Branch Loss Transfer Recapture
      • Treatment of Deferred Foreign Income (One-Time Tax)
      • Example(s)
    • Rules Related to Passive and Mobile Income
      • GILTI/FDII
        • Global Intangible Low Taxed Income Inclusion (GILTI)
        • Deduction for Foreign Derived Intangible Income
      • Other Subpart F Modifications
        • Modification of Section 958(b)(4)
        • Modification of definition of U.S. Shareholder
        • Elimination of 30-Day control requirements
        • Other
      • Prevention of Base Erosion (outbound)
        • Section 936(h)(3)(B) changes
        • Hybrid Transaction Rules
        • No 1(h)(11) rate for "Inverted" companies
      • Modification Related to FTC System
        • Repeal of Section 902
        • Section 960 Determined in Annual Basis
        • Separate limitation basket for Foreign Branch Income
        • Source of Income from sales of Inventory
        • ODL Amendments
    • Inbound Transaction Rules
      • Base Erosion and Anti-Abuse Tax
      • Increase in Section 6038A Penalties
    • Other
      • Insurance Exception to PFCI Rules
      • Repeal of FMV Method of Interest Apportionment
  • Provisions impacting foreign income of U.S. persons/companies
  • Provisions impacting non-U.S. persons investing in the United States

Who Will Benefit?

  • CPAs, tax professionals and other qualified professionals with basic knowledge of, and interest in, international tax
  • Management accountants and business team members involved in corporate tax function

Enhanced On-Demand Format

This enhanced on-demand format incorporates interactive exercises and/or knowledge check questions to test the learner's understanding of key concepts shared through discussion points on slides and from the subject matter expert captured in the video recording.

System Requirements

About the Authors

David Sites, CPA

David Sites, International Technical Leader of Grant Thornton's Washington National Tax Office, has more than 17 years of experience working with U.S.-based multinationals, foreign-owned inbound U.S. corporations, closely held businesses and high net worth individuals.

Grant Thornton

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.