- NY Credits : 5.0
- TX Credits : 5.0
- IRS Enrolled Agent Credits : Federal Tax/Tax Related Matters - 5.0
- IRS Non-Credentialed Return Preparer Credits : Federal Tax Update - 5.0
International Taxes under the Tax Cuts and Jobs Act
International Tax has always presented challenges due to its technical complexity. The Tax Cuts and Jobs Act of 2017 (TCJA) further added to those challenges. There are significant changes to this area as well as modifications to long standing international tax concepts. This program provides an overview of the main international tax provisions contained within the TCJA. Tax practitioners will benefit from the discussion of all these provisions, including the new corporate tax deduction for foreign source dividends, the new tax on global intangible "low-taxed" income, the new deduction for foreign derived intangible income and the new tax on base erosion payments, i.e. the BEAT. There is also a discussion of the long-standing international provisions that were modified, such as the number of foreign tax credit baskets, the changes to the definition of "U.S. shareholder" and its impact on controlled foreign corporations. And in making the transition in international tax from a "credit" based system to a "participation exemption", the transition tax affecting deferred foreign income is also discussed. Seasoned international tax practitioners as well as those practitioners with a "need-to-know" international tax, will find program useful as well as interesting.
This course is most appropriate for the professional with detailed knowledge in international tax who may be at a mid-level position within an organization with operational or supervisory responsibilities, or both.
Upon successful completion of this course, the user should be able to:
identify the overall general impact of the TCJA, including the major shifts in the direction of U.S. international tax
identify the basic components of the dividend received deduction set forth in Section 245A
determine the general components of the Section 965 transaction tax
identify the significance of the repeal of Section 902
determine the significance of changes to the sourcing of income and expense rules
identify the similarities and differences between the two new concepts: Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income
identify the expanded definition of intangible property and explain its consequence
determine the potential significance and relevance of the BEAT provisions as regarding U.S. multinationals