Income Inclusion in International Tax
CFC income inclusion rules for Subpart F, NCTI, E&P, and PTEP — and how they affect U.S. shareholders.
Format
Online
NASBA Field of Study
Taxes
Level
Intermediate
CPE Credits
2.5
Author(s)
AICPA staff
Availability
1 year
Product Number
USITII26SSO
Understanding CFC income inclusion frameworks
Income inclusion rules can require U.S. shareholders of controlled foreign corporations (CFCs) to recognize income currently, even before cash is distributed. This course focuses on how Subpart F, net CFC tested income (NCTI), E&P, and PTEP concepts interact when analyzing CFCs.
Applying Subpart F and NCTI concepts
You will review categories of Subpart F income, including:
- Foreign personal holding company income
- Foreign base company sales income
- Foreign base company services income
You will also discover how NCTI acts as a minimum-tax framework for certain foreign income and how exclusions and high-tax rules can affect analysis.
Connecting E&P and PTEP rules
The concept of E&P as an economic measurement construct is explored as well as why it matters for Subpart F inclusions, distributions, and related international tax calculations. You will also cover:
- PTEP awareness
- Tracking responsibilities
- Ordering concepts to prevent the same income from being taxed twice
Hands-on learning to develop your skills
This course takes a practical approach to showing how income inclusion regimes interact, with examples and exercises that reinforce key inclusion and limitation rules.
Note: This program includes content from the U.S. International Tax Certificate.
Who Will Benefit
- Tax professionals who advise U.S. shareholders of CFCs
- International tax practitioners and reviewers
- CPAs and finance professionals working with foreign subsidiaries
- Professionals seeking a working understanding of Subpart F, NCTI, E&P, and PTEP concepts
Key Topics
- Controlled foreign corporations (CFCs)
- Subpart F income
- Net CFC tested income (NCTI)
- Earnings and profits (E&P)
- Previously taxed earnings and profits (PTEP)
- High-tax exception
- Section 959 ordering rules
Learning Outcomes
- Identify categories of Subpart F income.
- Differentiate net controlled foreign corporation tested income (NCTI) from other income regimes.
- Recognize E&P as a measurement construct.
- Identify previously taxed earnings and profits (PTEP).
- Analyze relationships across income inclusion rules.
Group ordering for your team
2 to 5 registrants
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