International Taxation

Chapter 1Overview of U.S. Corporate International Taxation

Learning objectives

• Recognize the comprehensive system of outbound (core) and inbound U.S. international taxation laws.
• Recognize the concepts of timing for income recognition.
• Identify the international tax provisions of the Tax Cuts and Jobs Act (TCJA) signed in December 2017.
• Recognize U.S. federal income tax benefits for U.S. exporters of U.S. property under the interest charge domestic international sales corporations (IC-DISC) regime.

Summary

This course will cover the fundamentals of U.S. corporate international taxation, with a primary focus on “outbound concepts” and technical tax issues. This course has been updated to cover the fundamental international tax provisions within the TCJA, including for international tax Treasury Regulations and Notices released through March 2019.

In general, the United States taxes U.S. persons on their worldwide income. The United States may grant the functional equivalent of an exclusion through a foreign tax credit or tax deduction. For example, under Section 936, a domestic corporation may offset hypothetical U.S. taxes on certain income connected with U.S. possessions against U.S. taxes that otherwise would be due.

Section 7701(b) contains methodical rules to define when an alien is a U.S. resident. Mere presence in the United States for 183 days in a taxable year may subject an alien to taxation on worldwide income for that year. In general, a domestic corporation, which ...