• U.S. tax residents
• Default entity classification
• Foreign tax credit
• Global intangible low-taxed income
• Passive foreign investment companies
• Fixed, determinable, annual, or periodical income
• Effectively connected income
Learning Objectives
When you complete this course, you will be able to: • Recognize the rules for determining who is a U.S. taxpayer.
• Recall the basic rules for allocation and apportionment of deductions.
• Recognize the need for a foreign tax credit.
• Identify the purpose of anti-deferral regimes.
• Distinguish between anti-deferral regimes that apply to controlled foreign corporations.
• Identify the U.S. taxation of fixed, determinable, annual, or periodical income of foreign persons.
• Identify the U.S. taxation of effectively connected income of foreign persons.
Major Topics
• U.S. tax residents
• Default entity classification
• Foreign tax credit
• Global intangible low-taxed income
• Passive foreign investment companies
• Fixed, determinable, annual, or periodical income
• Effectively connected income
