U.S. International Tax Foundations Certificate

Essential U.S. international tax knowledge

Cross-border tax issues can arise from global business activity, mobile workforces, foreign investments, and international entity structures. This fully refreshed, 11-course certificate program introduces foundational U.S. international tax concepts and the core regimes you’ll encounter when advising individuals and businesses with cross-border activity.

Updated for H.R. 1, commonly referred to as OBBBA, and related regulatory guidance, this program, a mix of basic- and intermediate-level courses, helps you build a strong basis in U.S. international taxation.

Exploring practical applications through scenario-based examples

Throughout the program, you’re exposed to a breadth of U.S. international tax concepts that will strengthen your confidence at work. Practical examples cover matters relating to:

• Individuals
• Foreign corporations
• Cross-border services
• Withholding
• Treaty concepts
• Income inclusions
• Reporting requirements
• Reorganizations
• Related-party transactions

Courses cover how various U.S. international tax rules operate, how they interact, and when additional review or escalation may be appropriate.

Digital badges to showcase your U.S. international tax expertise

As you progress through this program, you will earn AICPA digital badges, which verify your achievements, highlight specialized skills, and share your accomplishments with employers, clients, and professional networks.

You will earn a competency badge for each course completed, validating specific U.S. international tax knowledge and skills. Then, upon completion of the U.S. International Tax Foundations Certificate, you’ll earn a meta badge and signed certificate to demonstrate your proficiency in U.S. international tax.

Who Will Benefit

• Tax professionals building foundational knowledge of U.S. international tax
• CPAs working with international income, entities, or reporting
• Corporate tax professionals supporting multinational or inbound structures

Key Topics

• Residency
• Sourcing
• Entity classification
• Fixed, determinable, annual, or periodical income
• Effectively connected income
• Controlled foreign corporations
• Subpart F
• Net controlled foreign corporation tested income
• Passive foreign investment companies
• Previously taxed earnings and profits
• Foreign tax credits
• Dual consolidated losses
• Corporate transactions
• Base erosion and profit shifting
• Transfer pricing

Learning Outcomes

• Recognize the rules for determining who is a U.S. taxpayer.
• Identify the purpose of anti-deferral regimes.
• Identify the U.S. taxation of effectively connected income (ECI) of foreign persons.
• Identify when an entity meets controlled foreign corporation criteria.
• Differentiate net controlled foreign corporation tested income (NCTI) from other income regimes.
• Recognize the need for a foreign tax credit (FTC).
• Identify the structure of passive foreign investment companies (PFICs).
• Identify situations in which dual consolidated losses (DCLs) arise.
• Analyze cross-border corporate transaction risks and when escalation is appropriate.
• Identify transfer pricing risk factors in cross-border related-party transactions.
• Analyze inbound and outbound tax effects of cross-border and business activity.