U.S. Taxation of International Transactions from Coursera

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Syllabus

Module 1: Introduction, Jurisdictional Principles, and Sourcing

In this module, you will first become familiar with the course, your instructor and your classmates, and our learning environment. This orientation will also help you obtain the technical skills required to navigate and be successful in this course. Next, we will begin our discussion of U.S. international taxation by discussing the baseline theories used to prevent international double taxation and the different jurisdictional bases for imposing taxation on international transactions. We will then discuss specific tests to determine when a taxpayer is a U.S. resident vs. non-resident. We will discuss system of worldwide taxation generally employed by the United States and major exceptions to that system. And, we will conclude with a discussion of how income is "sourced" to either the United States or a foreign jurisdiction using the sourcing rules of the United States.

Module 2: Inbound Taxation, Treaties, Transfer Pricing, and Export Incentives

In this module we will start with a basic introduction to inbound taxation issues, including a discussion of the Fixed, Determinable, Annual, and Periodical (FDAP) Income and Effectively Connected Income (ECI) taxing regimes. We'll then discuss the branch profits tax, which supports the ECI taxing regime. Next, we'll turn to understanding how tax treaties impact existing international taxation rules. Then, we'll cover transfer pricing issues, including a discussion of the new Base Erosion and Anti-Abuse Tax (BEAT). We'll conclude with a discussion of export incentives available to U.S. taxpayers selling abroad.

Module 3: Controlled Foreign Corporations and Current Income Inclusions

In this module we will be introduced to the Subpart F and Global Intangible Low Taxed Income (GILTI) regimes. These taxing regimes will cause certain foreign income earned by U.S. Shareholders through Controlled Foreign Corporations (CFCs) to be currently taxable in the United States. Specifically in this module we will learn to identify when a U.S. person is a U.S. Shareholder and when a foreign corporation is a CFC. We will also learn about what types of income constitute Subpart F. And, how GILTI is computed. We will conclude with a discussion of the Passive Foreign Investment Company (PFIC) rules which cover U.S. persons investing in foreign corporations that are not CFCs.

Module 4: The Foreign Tax Credit

In this module we will learn about how the Foreign Tax Credit mitigates the possibility of international double taxation. We will learn what foreign taxes are creditable for purposes of this tax. We will then turn to computing the Foreign Tax Credit Limitation, which ensures that foreign taxes paid or accrued are only used to offset U.S taxes on foreign income and not U.S. taxes on U.S.-sourced income. We will then discuss how the Foreign Tax Credit interacts with provisions we have already discussed (e.g., GILTI). We will conclude with a brief discussion of the Check-the-box Rules and how they impact international tax planning.

Good to know

Know what's good

, what to watch for

, and possible dealbreakers

Provides introduction for the U.S. persons who are complete new to the international taxation rules

Provides insightful examples and case studies that helps students to analyze the real world scenarios of international taxation

Students will learn how to apply tax treaties for mitigating double taxation

Helps in learning the complete process for calculation of foreign tax credits and global intangible low taxed income

Provides in-depth knowledge of Passive Foreign Investment Company (PFIC) rules

Requires prior understanding of basic U.S. federal taxation before enrolling in the course

Activities

Be better prepared before your course. Deepen your understanding during and after it. Supplement your coursework and achieve mastery of the topics covered in U.S. Taxation of International Transactions with these activities:

Organize and review course materials

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Improve your understanding and retention by organizing and reviewing course materials.

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Compile all course materials, including notes, assignments, quizzes, and exams.
Organize the materials into logical sections or topics.
Review the materials regularly to reinforce your learning.

Provide guidance and support to other students in the course

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Enhance your understanding by helping others and solidifying your knowledge.

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Identify opportunities to help other students by answering questions or sharing insights.
Provide constructive feedback and guidance to other students.
Participate in online forums or study groups to connect with other students.

Prepare a PPT presentation on controlled foreign corporations

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Enhance your understanding of CFCs by creating a structured presentation.

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Identify the key concepts and rules related to controlled foreign corporations.
Structure the PPT presentation with clear sections and logical flow.
Develop visuals and graphics to enhance the presentation's clarity.
Practice delivering the presentation to improve your confidence and clarity.

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Simulate an international tax planning scenario

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Apply your knowledge to a practical scenario and develop a comprehensive tax plan.

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Identify a real-world business scenario involving international operations.
Analyze the tax laws and regulations applicable to the scenario.
Develop a tax plan that optimizes the tax position of the business.
Present your tax plan to a group of peers or professionals for feedback.

Career center

Learners who complete U.S. Taxation of International Transactions will develop knowledge and skills that may be useful to these careers:

Transfer Pricing Analyst

Transfer Pricing Analysts develop and implement transfer pricing policies for multinational corporations. This course provides a deep understanding of the transfer pricing rules and regulations that govern cross-border transactions between related parties. This knowledge is essential for Transfer Pricing Analysts to ensure that their companies comply with tax laws and optimize their tax positions.

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International Tax Lawyer

International Tax Lawyers advise clients on the tax implications of cross-border transactions and investments. This course provides a comprehensive overview of the U.S. tax rules that apply to international transactions, including the source of income, transfer pricing, and controlled foreign corporations. This knowledge is essential for International Tax Lawyers to help their clients navigate the complex legal and tax landscape of international business.

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International Tax Compliance Manager

International Tax Compliance Managers oversee the tax compliance of multinational corporations. This course provides a comprehensive understanding of the U.S. tax laws that apply to international businesses, including the foreign tax credit, Subpart F income, and GILTI. This knowledge is essential for International Tax Compliance Managers to ensure that their companies comply with tax laws and avoid penalties.

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International Tax Accountant

International Tax Accountants specialize in the complex tax regulations that govern international business transactions. This course provides a strong foundation in the U.S. tax treatment of international transactions, including transfer pricing, controlled foreign corporations, and the foreign tax credit. This knowledge is essential for International Tax Accountants to advise multinational corporations on how to comply with tax laws and minimize their tax liability.

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Tax Policy Analyst

Tax Policy Analysts develop and analyze tax policies for governments. This course provides a strong foundation in the principles of international taxation, including the source of income, transfer pricing, and the foreign tax credit. This knowledge is essential for Tax Policy Analysts to understand the impact of tax policies on international businesses and economies.

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International Business Consultant

International Business Consultants advise businesses on how to expand their operations globally. This course provides a comprehensive overview of the tax and legal issues that businesses face when operating internationally. This knowledge is essential for International Business Consultants to help their clients succeed in the global marketplace.

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Foreign Exchange Trader

Foreign Exchange Traders buy and sell currencies on behalf of banks, investment firms, and other clients. This course provides a strong understanding of the economic and political factors that affect currency exchange rates. This knowledge is essential for Foreign Exchange Traders to make informed trading decisions and manage risk.

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Global Mobility Specialist

Global Mobility Specialists help businesses manage the tax and legal issues associated with relocating employees internationally. This course provides a comprehensive understanding of the tax rules that apply to expatriates and the tax implications of cross-border employee benefits. This knowledge is essential for Global Mobility Specialists to help their clients comply with tax laws and minimize their tax liability.

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Customs Broker

Customs Brokers help businesses import and export goods across borders. This course provides a strong understanding of the customs regulations and procedures that govern international trade. This knowledge is essential for Customs Brokers to help their clients comply with customs laws and avoid penalties.

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International Development Specialist

International Development Specialists work with governments and organizations to promote economic and social development in developing countries. This course provides a strong foundation in the principles of international taxation, including the source of income and the foreign tax credit. This knowledge is essential for International Development Specialists to understand the impact of tax policies on developing countries and to design effective development programs.

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Corporate Tax Accountant

Corporate Tax Accountants prepare tax returns and advise businesses on tax matters. This course provides a strong foundation in the principles of international taxation, including the source of income and the foreign tax credit. This knowledge is essential for Corporate Tax Accountants to help their clients comply with tax laws and minimize their tax liability.

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Investment Banker

Investment Bankers advise companies on mergers and acquisitions, capital raising, and other financial transactions. This course provides a strong understanding of the tax implications of cross-border transactions, including the source of income, transfer pricing, and the foreign tax credit. This knowledge is essential for Investment Bankers to help their clients structure transactions in a tax-efficient manner.

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Forensic Accountant

Forensic Accountants investigate financial crimes and fraud. This course provides a strong foundation in the principles of international taxation, including the source of income and the foreign tax credit. This knowledge is essential for Forensic Accountants to understand the complex tax issues that can be involved in financial crimes and fraud.

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Tax Auditor

Tax Auditors examine tax returns and conduct audits to ensure compliance with tax laws. This course provides a strong foundation in the principles of international taxation, including the source of income and the foreign tax credit. This knowledge is essential for Tax Auditors to understand the complex tax issues that multinational businesses face.

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Financial Analyst

Financial Analysts evaluate the financial performance of companies and make investment recommendations. This course provides a strong foundation in the principles of international taxation, including the source of income and the foreign tax credit. This knowledge is essential for Financial Analysts to understand the impact of tax policies on companies and to make informed investment decisions.

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