Fundamentals of Outbound US Rules of International Taxation 2024
4.00 Credits
Member Price $159
Non-Member Price $209
Overview
This program will begin the jurisdictional basis for the assertion of the US taxing jurisdiction over US persons. After a discussion of the foreign tax credit rules and the anti-deferral regimes (Subpart F, GILTI, and PFIC), Mr. Misey will discuss export benefits (IC-DISCs and the FDII deduction).
Highlights
- The US Taxing Jurisdiction
- Sourcing Rules
- Foreign Tax Credits
- Subpart F
- Global-Intangible Low-Taxed Income
- Passive Foreign Investment Companies
- IC-DISCs
Prerequisites
None
Designed For
CPAs and tax professionals that deal with international tax issues.
Objectives
- Identify issues with respect to cross border transactions
- Determine how the U.S. rules eliminate double taxation
- Recognize opportunities for tax minimization strategies
Preparation
None
Leader(s):
Leader Bios
Robert Misey Jr., CalCPA Education Foundation
Robert Misey is a shareholder with Reinhart Boerner Van Deuren s.c. He practices in the areas of international taxation and tax controversies. His previous experience includes nine years as an international trial attorney for the IRS in San Jose and in Washington, DC where he tried 21 Tax Court cases and served on the industry programs for both the athletics and entertainment industries and the manufacturing industries. He also led the international tax group for a region of a Big Four accounting firm. Misey received his bachelor’s degree from the University of Kentucky, his juris doctor and master of business degrees from Vanderbilt University, and his master of laws in taxation from Georgetown University. He is a co-author to the treatises U.S. Taxation of International Transactions and Federal Taxation: Practice and Procedure, and a member of the bar in California, Kentucky and the District of Columbia.
Non-Member Price $209
Member Price $159