Structuring Foreign Business Activities of United States Taxpayers

Explore the fundamental concepts of how United States taxpayers are taxed on multinational income in this engaging course designed exclusively for attorneys. This comprehensive program offers an in-depth overview of the intricate rules and regulations governing foreign-sourced income U.S. taxpayers earn.

Throughout the course, participants will gain a deep understanding of key topics, including the nuances of Controlled Foreign Corporation (CFC) rules, considerations related to Passive Foreign Investment Companies (PFICs), and the advantageous aspects of the Foreign-Derived Intangible Income (FDII) deduction.

Tailored for attorneys who represent clients with multinational income, this program provides valuable insights into both planning opportunities and crucial information and income reporting requirements. Legal professionals who are new to the field or seeking to refresh their knowledge, this course will equip them with the essential expertise needed to navigate the complex landscape of U.S. taxation of multinational income. This informative program will enhance an attorney's skills to better serve their clients.

Learning Objectives:

• Evaluate how foreign business entities are classified for United States tax purposes
• Analyze the rules for United States taxpayers with interests in controlled foreign corporations
• Examine rules for United States taxpayers with interests in passive foreign investment companies
• Comprehend how the foreign-derived intangible income deduction is applied
• Identify the business structuring options for multinational activities