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01 - 03 Apr 2019US Corporate Taxation

This course provides participants with an essential overview and a comprehensive understanding of the complex US tax system, with particular emphasis on international aspects. The main focus of the course is on US corporate taxation and cross-border issues faced by US-based multinationals.
 
Type:
Tax Courses
Language:
English
Location:
Amsterdam - The Netherlands
Level:
Intermediate
Course code:
OC19USCT1
Price:
EUR 2,297 / USD 2,756 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
 
Early Bird Discount: a 30% discount will be automatically applied for registrations received 60 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
 
US Corporate Taxation

Overview and learning objectives

This course provides participants with an essential overview and comprehensive understanding of the complex US tax system, with particular emphasis on international aspects. The main focus of the course is on US corporate taxation and cross-border issues faced by both US-based and foreign-based multinationals. The United States is well known for its complex income tax system. Multinational corporations (MNCs) are faced with the complexities of different tax jurisdictions as they expand globally. To remain competitive, they need to examine the tax implications of their business strategies in all jurisdictions in which they conduct, or plan to conduct, business.

This course intends to bridge the gap between US and local tax implications for tax practitioners to facilitate their day-to-day work, and provide an overview and a good understanding of the mechanisms of the US tax system including its terms and concepts. Particular emphasis will be put on international tax aspects faced by the multinationals balancing their US and foreign tax positions. Major US inbound and US outbound tax topics will be covered, including treaty benefits and relief from double taxation.

The speakers for the course will give particular emphasis to the extensive revisions made to the US international tax system by the Tax Cuts and Jobs Act (TCJA) adopted by the United States at the end of 2017, including the new rules of global intangible low-taxed income (GILTI), the participation exemption resulting from the 100% deduction for foreign-source dividends, the new base erosion anti-abuse tax (BEAT), the new rules for foreign-derived intangible income (FDII), the new interest deduction limitation that replaces the US earnings-stripping rule, the anti-abuse rules for hybrid entities and hybrid transactions, the revisions to the US foreign tax credit system, and the transition tax for deferred offshore income of CFCs as the United States moves to a more territorial system.

This is an interactive course and participation is limited to a maximum of 32 participants. Prior to the course, all course material will be sent to participants in a digital format. Participants will have access to an online study collection for two weeks from the start of the course.

Field of study

Taxes
 

Who should attend?

The course is suitable for practitioners in tax advisory firms, corporate tax directors and managers, accountants, CPAs, attorneys, and other corporate finance executives and government officials who wish to both understand and examine practical solutions for complex US cross-border tax issues.

Course level and prerequisites

This is an introductory/intermediate-level course. Although participation in the course does not require prior experience or knowledge about the US tax system, participants should have some understanding of general principles of taxation, including international aspects.
 

Pre-course preparation

In order to participate in this particular course, no advance preparation is necessary. However, for some courses, suggested reading materials will be made available on our online platform a few weeks before the start of the course.

Interactive course - "Group Live"

This is an intermediate-level course. Although participation in the course does not require prior experience or knowledge about the US tax system, participants should have some understanding of general principles of taxation, including international aspects.

We invite you to send us in advance any technical, content-related questions you may have. During the course we will try to address your specific questions, but please note that this will depend on the amount of time available, the relevance of the questions and the order in which the questions are received.

Should you have a question, please send it to taxcourses@ibfd.org.

Disclaimer: The information provided during the course has been prepared solely for the instruction of course participants. This information is not intended to constitute advice on any particular matter.

Continuing professional education

Recommended NASBA CPE points for this course: 19.5 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for IBFD International Tax Courses.

Course fee and registration details

The course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.

 

  • Introduction to US tax system
  • Forms of doing business
  • US tax treaties
  • Double taxation relief
  • Foreign activities of US corporations
  • US taxation of foreign corporations
  • Case studies
  • Mindy Herzfeld is Professor of Practice at University of Florida Levin College of Law, where she teaches International Taxation and Tax Policy to LLM students. She also serves as contributing...
  •  
    Michael Lebovitz is a partner in the tax transactions and consulting practice of the international law firm Mayer Brown. Based in Los Angeles, he is part of Mayer Brown’s global tax...
  •  
    John G. Rienstra is the Chief US Tax Lawyer for IBFD. He is involved in research projects on a great variety of topics, lectures on US and International Tax Law, and is author of several high-level...
  • Robert Goulder
    Robert Goulder is Senior Tax Policy counsel with Tax Analysts. He previously served as editor-in-chief of Tax Analysts’ international publications. In that capacity, he coordinated coverage...