Individuals in the U.S. International Tax System
Cross-border tax rules for individuals, including residency, mobility, business and employment income, portfolio investment, treaty relief, FIRPTA, FATCA, and transfer tax considerations.
Format
Online
NASBA Field of Study
Taxes
Level
Intermediate
CPE Credits
3
Author(s)
Genevieve Tokic
Availability
1 year
Product Number
USITIITS26SSO
Navigating individual cross-border taxation
Individuals who live, work, invest, or do business across borders face complex U.S. international tax rules. This course helps learners connect the rules related to residency, sourcing, treaties, and regimes to common inbound and outbound scenarios.
Learners explore core cross-border tax concepts, including:
- Individual cross-border tax scenarios
- Double taxation relief through exclusions, credits, and treaties
- Inbound and outbound tax considerations for individuals
Residency and mobility matters
Residency status can quickly change the scope of an individual’s U.S. tax exposure. And in an increasingly globalized economy, mobility is more salient than ever.
Materials help learners determine the tax implications of topics, including:
- U.S. citizenship, green card status, and the substantial presence test
- Treaty residency, tie-breaker rules, and the saving clause
- Expatriation
Income and investment considerations
Learners also examine the tax treatment of cross-border business and employment activity, along with the rules that apply to portfolio investments held across borders.
Income and investment topics include:
- Foreign tax credits and the foreign-earned income exclusion
- Permanent establishment and business profits concepts
- Partnership attribution and treaty treatment of pass-through entities
- Passive foreign investment companies (PFICs), Subpart F, and net controlled foreign corporation tested income (NCTI) rules
Reporting and withholding rules
The course also addresses compliance and withholding regimes that may apply when individuals invest, earn income, or hold assets across borders.
Reporting and withholding topics include:
- Fixed, determinable, annual, or periodical (FDAP) income withholding and treaty rate reductions
- Foreign Investment in Real Property Tax Act (FIRPTA) and U.S. real property interests
- Foreign Account Tax Compliance Act (FATCA) reporting and withholding rules
- U.S. estate and gift tax exposure for nonresident aliens
Who Will Benefit
- CPAs and tax practitioners advising individuals with cross-border activity
- International tax professionals working with inbound or outbound individual tax matters
- Personal financial planning professionals advising globally mobile clients
- Finance and accounting professionals supporting internationally active individuals
Key Topics
- Individual cross-border tax scenarios
- U.S. tax residency and treaty tiebreakers
- Foreign-earned income exclusion and foreign tax credits
- Cross-border business and employment income
- Permanent establishment and business profits concepts
- PFICs, Subpart F, and net CFC tested income rules
- FDAP withholding, FIRPTA, and FATCA
- Estate and gift tax exposure for nonresident aliens
Learning Outcomes
- Identify cross-border tax scenarios affecting individuals.
- Determine the effect of residency and mobility on an individual’s taxation.
- Analyze inbound and outbound tax effects of cross-border and business activity.
- Select the provisions that affect cross-border portfolio investment.
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2 to 5 registrants
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