Intermediate U.S. International Tax for Non-International Tax Professionals
BNA Tax & Accounting Conferences
May 20, 2009
Douglas Stransky discussed U.S. tax issues for companies seeking to expand internationally. This program offered a more in-depth overview of international taxation than the basic “Introduction to U.S. International Tax for Non-International Tax Professionals” and was designed as either a stand alone program or a continuation of the introductory course.
The objectives of Mr. Stransky's 90 minute audio discussion included providing participants with a conceptual understanding and practical application of the following:
- Outbound Transfers under Code section 367
- The Foreign Tax Credit
- Subpart F and PFIC Rules
- Code section 1248
- Code section 482 and Transfer Pricing Overview
- Tax Treaties and Code section 894
- Outbound Tax Planning
- U.S. Taxation of Foreign Persons