Table of Contents
1 Cover
2 Chapter 1: Overview of U.S. Corporate International Taxation Summary U.S. Outbound Tax Concepts U.S. Inbound Tax Concepts Other fundamental U.S. international tax concepts International tax fundamental concepts Recognition of income Introduction of International Tax Provisions enacted by the TCJA Introduction and listing of U.S. international tax provisions U.S. Export Tax Incentive through an IC-DISC
3 Chapter 2: Foreign Branches Operating through a foreign branch — summary Form 8832, “Entity Classification Election”—“check-the-box” election Threshold of liability to foreign tax Foreign currency issues as applied to branches, or QBUs QBU Section 988 transactions Dispositions of nonfunctional currency Translations with respect to debt instruments U.S. dollar approximate separate transactions method
4 Chapter 3: Determining Source of Income Personal property
5 Chapter 4: Allocation and Apportionment of Deductions Allocation and apportionment of expenses, losses, and other deductions to U.S. and foreign-source income Allocation and apportionment of certain deductions Allocation and apportionment of interest expense Special apportionment rules for partnerships Special apportionment rules for corporations Special allocations of interest expense Research and experimentation expenditures Notes
6 Chapter 5: U.S. Foreign Tax Credit System FTC system post-TCJA overview and status Internal Revenue Code sections dealing with foreign taxes FTC expanded rules and examples Creditable foreign taxes Timing and recognition issue Partnerships, LLCs (taxed as U.S. partnerships), and S corps Note
7 Chapter 6: Outbound International Tax Provisions under Tax Cuts and Jobs Act Note to Reader or Practitioner CFCs and Subpart F — Outline Foreign base company sales income—Examples FBC Services Income—Example and details TCJA outbound international tax provisions PFICs Transfers of property by U.S. persons to foreign corporations — Section 367
8 Chapter 7: Inbound Taxation: U.S. Withholding Tax & Tax Treaty Concepts Threshold for U.S. inbound taxation U.S. trade or business > Effectively Connected Income (ECI) Thin capitalization — interest expense limitation rules FIRPTA — Section 897 U.S. inbound tax reporting obligations IRC Chapter 3 — U.S. source withholding tax IRC Chapter 3 withholding tax rules FDAP (not ECI) FDAP — Interest payment FDAP — Dividends FDAP — Royalties FDAP — Rents FDAP — Compensation for services FDAP income Gains from sale of personal property (for example, capital gains) ECI exemption Withholding tax obligations and procedures
