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Fundamentals of Corporate Outbound Taxation: Boot Camp

Information Reporting Requirements, Anti-Deferral Rules, Income Sourcing, Discerning Global From Territorial Tax

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Wednesday, January 15, 2020

Recorded event now available

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.

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.

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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

Faculty

Loizeaux, James
James Loizeaux
Managing Director, Global Tax Services
CliftonLarsonAllen

Mr. Loizeaux has more than 25 years of public accounting and industry experience in international corporate tax. He has...  |  Read More

Samtoy, John
John Samtoy
Tax Partner
Holthouse Carlin & Van Trigt

Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on...  |  Read More