2023-2024 Catalog

TAX-865 International Taxation Outbound

This course studies the U.S. taxation of U.S. persons with non-U.S. income and or activities, or both. The course examines foreign tax credit principles and includes hands on application of the foreign tax credit limitation rules. The course covers individuals with earned foreign income, controlled foreign corporations, and provides an overview of earnings and profits, tested income, Subpart F income and investment in U.S. property. The curriculum of the course has been revised to incorporate the substantial additions and modifications to the U.S. international tax system resulting from the Tax Cuts and Jobs Act including the Global Intangible Low Tax-Taxed Income (GILTI), Base Erosion and Anti-Abuse Tax (BEAT) and the Foreign-Derived Intangible Income (FDII). The curriculum includes foreign currency issues, an overview of income tax treaties, other current international tax issues, and addresses compliance and disclosure requirements. The course incorporates tax practice by employing a case study that allows hands on application of the course curriculum as it relates to the calculation and reporting of non-U.S. transactions and the completion of relevant tax forms.




TAX-801 and TAX-862 or approval of the MST Director