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Course Overview This two day course covers the principles of US taxation of business activity. Concentration on the effects of inbound and outbound investment will enhance the understanding of the tax consequences and opportunities when business is carried on in the USA and when US based corporations expand out of the USA. The course moves through consideration of the causes of US tax, and the computation of US taxable income to the US approach to tax treaties. The two day structure of the course recognises the complexity of the material and is designed to allow time for questions and discussions. The course requires an understanding of the principles of international taxation. Course Outline DAY 1
CAUSES OF US TAX LIABILITY - US residence
- US trade or business and effectively connected income
- US source investment income
DOING BUSINESS IN THE USA - US business forms and classification
- US branches and the branch profits tax
- US subsidiary companies, taxation of companies
TAX COMPLIANCE - The taxable year
- Accounting methods
- Due dates and filing extensions
- Calculation of taxable income
- Alternative minimum tax
- Supplementary information, transactions with related parties
- Penalties and interest
CONSOLIDATED TAX RETURNS STATE TAX ISSUES DAY 2
INVESTMENT INTO THE USA - Structure of the investment, acquisition shares versus assets, restrictions on the carry forward of losses
- Reorganisations and mergers
- Financing issues, debt versus equity, acquisition indebtedness, earnings stripping rules
- Repatriation of profits
- Sale of US investment
INVESTMENT FROM THE USA - Taxation of overseas operations, branch versus partnership, classification of entities
- Foreign tax credits and limitations on use
- Controlled foreign corporations
- Current recognition of overseas income through Subpart F and Passive Foreign Investment Companies
- Sales of overseas operations
TAX TREATIES - The approach to tax treaties, and the anti-treaty shopping rules included in the more recent treaties
How to make a booking for the F-ICT-US course
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