International Tax Provisions in the 2017 Tax Cuts and Jobs Act

Authored by Robert Misey
About this Course
Topics covered include: Deemed repatriation of accumulated earnings at the end of 2017; Changes to sourcing rules that can result in double taxation to U.S. manufacturers; The base erosion rules; The participation exemption for foreign-source dividends received by C corporations; Pass-through provisions that impact the IC-DISC benefit; Provisions to keep intangibles in the United States. Upon completing this course, you should be able to: Identify the international tax provisions of the Tax Cuts and Jobs Act of 2017; Discuss and implement planning techniques to help your clients or business; Recognize the foreign-source dividend participation exemption; Differentiate when deferral of the deemed repatriation tax does not apply; Identify when a super-charged IC-DISC is more advantageous than a classic IC-DISC; Recognize how the 2017 Tax Cuts and Jobs Act (the Act) changed the subpart F rules; Identify why U.S. exporters will be paying higher tax under the provisions of the 2017 Tax Cuts and Jobs Act; Differentiate when determining the amount of income from a U.S. subsidiary that is subject to the base erosion anti-abuse tax (BEAT); Recognize the statute of limitations for the payment of the deemed repatriation tax; Identify what the 2017 Tax Cuts and Jobs Act added to the list of 936(h)(3)(B) intangibles; Recognize when the the downward attribution rules for foreign persons does not apply; Identify what the 2017 Tax Cuts and Jobs Act eliminates; Recognize what is included in Subpart F income; Differentiate the four allocation 'baskets' for the foreign tax credit; Identify what the new Section 163(j) does not allow for; Recognize how base erosion abuse and BEAT are applied; Describe what the anti-hybrid statute affects; Differentiate statements applied to C-Corporations.
$ 34.00
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NASBA Field of Study
CPE Credits
Basic understanding of federal international taxation issues.
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