Introduction to International Taxation  

Upon successful completion of this course, the user should be able to:

• identify the income-sourcing rules in international tax planning and compliance work,

• recognize the importance of citizenship and residence in determining tax liabilities of individuals,

• identify which foreign entities and types of income are subject to special rules,

• recognize the general purpose and basic calculations of Subpart F and the characteristics of a controlled foreign corporation,

• identify the tax treatment of U.S. corporations with foreign ownership,

• recognize how the U.S. foreign tax credit system works, cite the general requirements for withholding U.S. income tax on certain types of income paid to foreign persons, and

• recognize the organizational structure of income tax treaties.