International Taxation: Inbound Transactions
An examples-based discussion of key concepts, including effectively connected income, branch profits tax (BPT), branch-level interest tax, Form 1120-F, and more.
Format
Online
NASBA Field of Study
Taxes
Level
Intermediate
CPE Credits
6
Author(s)
Lincoln Terzian, Jose Alicea, David Zaiken, David Balaban
Availability
1 year
Product Number
ITCG25SSO
Inside inbound investment transactions
Foreign investments in U.S. entities are known as inbound transactions. This CPE self-study course covers the many concepts necessary to understand the U.S. federal income taxation of inbound transactions, including:
- Effectively connected income (ECI)
- Branch profits tax (BPT)
- Branch-level interest tax
- Treaty-based form compliance
- Income sourcing
- Withholding tax
FATCA and FIRPTA decoded
The Foreign Account Tax Compliance Act (FATCA) and the Foreign Investment in U.S. Real Property Tax Act of 1980 (FIRPTA) impose requirements that affect inbound transactions. This course provides an examples-based explanation of FATCA and FIRPTA rules and exceptions.
Part of a comprehensive international tax education
This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation.
This course can be purchased individually or as part of the U.S. International Tax: Inbound and Outbound Transactions bundle. You must purchase the bundle to earn the digital badge.
Who Will Benefit
Public and corporate tax professionals interested in building a solid foundation in U.S. international taxation.
Key Topics
- Effectively connected income
- Branch profits tax
- Income sourcing
- Withholding requirements
- Foreign Account Tax Compliance Act (FATCA)
- Foreign Investment in U.S. Real Property Tax Act of 1980 (FIRPTA)
- U.S. real property interest (USPRI)
Learning Outcomes
- Identify the tax consequences of having U.S. effectively connected income (ECI).
- Determine whether an activity constitutes U.S. trade or business.
- Determine the branch profits tax (BPT) and branch-level interest.
- Identify the basics of tax withholding for nonresident aliens and taxation under the Foreign Account Tax Compliance Act of 2010 (FATCA).
- Identify how to determine the character and source of income for different payment types.
- Identify a withholding agent and the rules that apply to withholding agents.
- Determine when the Foreign Investment in Real Property Tax Act (FIRPTA) applies and does not apply.
- Identify FIRPTA exclusions and exceptions with respect to U.S. real property interests (USRPIs).
Group ordering for your team
2 to 5 registrants
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