International Tax Provisions in the 2017 Tax Cuts and Jobs Act (Currently Unavailable)

Author: Robert J. Misey, Benjamin B. Genzer

International tax issues were the driving force behind the Tax Cuts and Jobs Act of 2017. As with all tax legislation, the international provisions create winners, losers, and traps for the unwary. This two-hour CPE course with Robert Misey and Benjamin Genzer will help you to assist your clients that have activities crossing international borders. Now is the time to get up to speed on these critical changes and prepare your business or clients for 2018.

This course reflects tax law after enactment of TCJA.

Publication Date: January 2018

Designed For
All CPAs, EAs, tax professionals and corporate tax and financial professionals who are involved in tax planning and compliance for cross border businesses.

Topics Covered

• Deemed repatriation of accumulated earnings at the end of 2017
• Changes to sourcing rules that can result in double taxation to U.S. manufacturers
• The base erosion rules
• The participation exemption for foreign-source dividends received by C corporations
• Pass-through provisions that impact the IC-DISC benefit
• Provisions to keep intangibles in the United States

Learning Objectives

• Identify the international tax provisions of the Tax Cuts and Jobs Act of 2017
• Discuss and implement planning techniques to help your clients or business
• Recognize the foreign-source dividend participation exemption
• Differentiate when deferral of the deemed repatriation tax does not apply
• Identify when a super-charged IC-DISC is more advantageous than a classic IC-DISC
• Recognize how the 2017 Tax Cuts and Jobs Act (the Act) changed the subpart F rules
• Identify why U.S. exporters will be paying higher tax under the provisions of the 2017 Tax Cuts and Jobs Act
• Differentiate when determining the amount of income from a U.S. subsidiary that is subject to the base erosion anti-abuse tax (BEAT)
• Recognize the statute of limitations for the payment of the deemed repatriation tax
• Identify what the 2017 Tax Cuts and Jobs Act added to the list of 936(h)(3)(B) intangibles
• Recognize when the the downward attribution rules for foreign persons does not apply
• Identify what the 2017 Tax Cuts and Jobs Act eliminates
• Recognize what is included in Subpart F income
• Differentiate the four allocation 'baskets' for the foreign tax credit
• Identify what the new Section 163(j) does not allow for
• Recognize how base erosion abuse and BEAT are applied
• Describe what the anti-hybrid statute affects
• Differentiate statements applied to C-Corporations

Level
Update

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic understanding of federal international taxation issues.

Advance Preparation
None