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Corporate Taxation in the USA - Outbound Taxation

Course

In City of London ()

£ 575 + VAT

Description

  • Type

    Course

  • Duration

    1 Week

This covers the principles of the US taxation on business activity. Day One focuses on the outbound US taxation, whilst the separately bookable day-two concentrates on inbound taxation. Suitable for: Those needing a basic background in the US corporate tax system. The course requires delegates to have an understanding of the principles of international taxation.

About this course

The course requires delegates to have an understanding of the principles of international taxation.

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Subjects

  • Business Income
  • VAT
  • National Insurance
  • Auditing
  • Company Tax
  • Check-the-Box
  • Source of Income
  • Tax Rates
  • Consolidated Returns
  • IT
  • Communication Skills

Course programme

Course review:

This covers the principles of the US taxation on business activity. Day One focuses on the outbound US taxation, whilst the separately bookable day-two concentrates on inbound taxation.

COURSE CONTENT

General US Tax Concepts

  • Classification and Taxation of Entities
  • Check-the-Box
  • Source of Income

Determination of US Federal Tax Liability

  • Book Income vs. Taxable Income
  • Tax Rates
  • Alternative Minimum Tax
  • Consolidated Returns
  • Brief overview of State Taxation
  • Walkthrough of Form 1120 (US Corporate Tax Return)

Controlled vs. Non-Controlled Foreign Corporations

  • Non-Controlled Corporations – PFICs
  • Controlled Foreign Corporations

    - Subpart F Income

    - Investment in US Property

  • Foreign Tax Credits
  • Walkthrough of Forms 5471 and 8858

Distributions of Cash and Property

  • Introduction to Earnings and Profit
  • Definition of Dividend vs. Return of Capital vs. Capital Gain
  • Deemed Distributions

Incorporation of a Company

  • General Tax-Free Rules
  • Treatment of Boot
  • Application of Tax-Free Rules in Multinational Context

Tax-Free Reorganizations

  • Overview of Tax-Free Reorganizations
  • Overview of Tax Consequences of Tax-Free Reorganizations
  • Tax Deferred Share-for-Share Exchanges
  • Tax Deferred Asset Acquisitions

Liquidations

  • Taxable Liquidations
  • Tax-Free Liquidations
  • Liquidations in the Outbound Context

Corporate Taxation in the USA - Outbound Taxation

£ 575 + VAT