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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Wednesday, January 15, 2020

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$247.00

This course will provide tax advisers and compliance professionals with a sound foundation for identifying the U.S. tax consequences and information reporting requirements of outbound transactions. The webinar will outline the anti-deferral regimes, rules for income sourcing, foreign tax credits, apportioning expenses, tax exposure in foreign jurisdictions, and information reporting requirements.

Faculty

Loizeaux James
Shareholder
CliftonLarsonAllen

Mr. Loizeaux has more than 25 years of public accounting and industry experience in international corporate tax. He has extensive technical expertise in complex international compliance, repatriation strategies, structuring foreign operations and exports – IC DISC. Prior to joining CLA, he was a Director with a major accounting firm and was the international tax manager for a multinational company responsible for the management of research, planning and compliance for foreign tax matters in foreign jurisdictions and related to U.S. income taxes. 

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Samtoy John
Shareholder
Holthouse Carlin & Van Trigt LLP

Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on individuals, closely-held businesses, and hedge funds. He has particular expertise in structuring and reporting foreign manufacturing arrangements and foreign holding companies, and is experienced in foreign asset disclosure requirements, as well as foreign trust and estate reporting.

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Description

Congress and Treasury continue to make sweeping changes to the reporting requirements for and taxation of cross-border activities by taxpayers subject to U.S. tax jurisdiction. Tax professionals must have a thorough grounding in the foundations of U.S. outbound taxation. The IRS has indicated that tracking compliance with foreign information reporting and income is among its highest priorities.

The framework of U.S. foreign income, asset, and tax reporting is intricate and complicated. Despite talk of movement toward a territorial tax regime, the U.S. still taxes its residents on worldwide income.. The U.S. outbound tax reporting regime consists of two major components: reporting of assets/holdings and reporting of income. In layman's terms, taxpayers subject to U.S. tax jurisdiction must report what they own and what they earn. However, determining whether a U.S. taxpayer has filing requirements can present a challenge to even seasoned tax advisers. So it is helpful to examine the reach of the taxing regime in terms of outbound (U.S. citizens and residents with activities outside the United States) activities.

Listen as our expert panel provides a solid grounding in the basics of U.S. outbound tax reporting, and the identification of reporting requirements, thresholds, and rules.

Outline

  1. Overview of U.S. Outbound Taxation
  2. Anti-Deferral Regimes Sourcing Rules and the Sourcing of Income
  3. Foreign Tax Credits and the Apportionment of Expenses
  4. Determination of Tax Exposure Across Jurisdictions
  5. U.S. Outbound Information Reporting Requirements

Benefits

The panel will discuss these and other relevant topics:

  • How the U.S. outbound tax reporting regime is structured Anti-deferral regimes including PFIC, GILTI, Subpart F, and 956 rules
  • Sourcing of income between jurisdictions for U.S. tax purposes
  • Types of information filings and how they intersect with one another, and with income filings
  • Coordination between the U.S. and other countries in identifying assets
  • Foreign tax credits
  • Thresholds for foreign information reporting filing requirements

NASBA Details

 

Learning Objectives

After completing this course, you will be able to:

  • Detail the thresholds for foreign assets, income, and activities that trigger tax information reporting requirements for U.S. resident and nonresident corporations
  • Discuss the structure of tax reporting rules for outbound activities
  • Discuss the intersection of FBAR with Forms 8938 (FATCA), 5472, and 8621 (PFIC)
  • Recognize various categories of income with their correlative reporting forms

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).