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Matthew Hutchens
This course analyzes the tax treatment, issues, planning techniques and underlying government policies involved in doing business internationally. The course incorporates concepts learned in all of the tax courses as they relate to the impact on cross-border outbound transactions (i.e., the taxation of US taxpayers doing business abroad). Topics include the source of income, transfer pricing, controlled foreign corporations (CFCs), Subpart F income, foreign tax credits, Global Intangible Low-Taxed Income (GILTI), Base Erosion and Anti-Abuse Tax (BEAT), and Foreign Derived Intangible Income (FDII). While this course focuses heavily on outbound transactions, some inbound rules (i.e., non-US taxpayers doing business in the United States) will be discussed. This course is an introductory course, so no prior knowledge of international taxation is required or expected. However, prior knowledge of U.S. federal taxation is necessary.
Register for this course and see more details by visiting:
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What's inside
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.
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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.
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Traffic lights
Traffic lights
Read about what's good
what should give you pause 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
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Reviews summary
U.s. international tax foundations
According to students, this course offers a comprehensive and well-structured overview of U.S. international taxation. Many highlight the instructor's ability to provide crystal clear explanations for complex topics like GILTI, Subpart F, and BEAT. Learners also appreciate the practical application of concepts, finding them directly applicable to their work. While largely positive, some caution that the course requires a very strong background in U.S. federal tax, and the pace can be fast. Recent reviews suggest the course material is regularly updated, ensuring its relevance in a dynamic field.
Material consistently updated with tax law changes.
"I loved how current the material felt, reflecting recent legislative changes."
"The course material is regularly updated, which is crucial in tax law."
"Truly an invaluable resource... relevant, and engaging."
Concepts directly useful for professional practice.
"I found the examples highly practical, directly applicable to my work."
"The practical application exercises reinforced my learning."
"I feel much more confident discussing these topics now."
Excellent at demystifying intricate international tax law.
"The instructor's explanations of complex topics like GILTI and Subpart F are crystal clear."
"Instructor is brilliant, making complex concepts like BEAT and FDII understandable."
"The instructor's ability to simplify complex regulations is unmatched."
Course content is dense and moves quickly.
"The content is dense, but the instructor breaks it down effectively. Some parts felt a bit rushed."
"Good course, but very demanding. The foreign tax credit module was particularly detailed."
"I struggled with some of the explanations... The pace was fast."
Demands robust U.S. federal tax background.
"It definitely assumes a strong background in U.S. tax, maybe more than just 'necessary' – more like 'expert'."
"You really need that prior U.S. federal tax knowledge to keep up."
"I would advise anyone taking this to ensure they have a solid grasp of fundamental US federal tax law beforehand."
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
Show steps
Improve your understanding and retention by organizing and reviewing course materials.
Show steps
-
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
Show steps
Enhance your understanding by helping others and solidifying your knowledge.
Show steps
-
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
Show steps
Enhance your understanding of CFCs by creating a structured presentation.
Show steps
-
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.
One other activity
Expand to see all activities and additional details
Show all four activities
Simulate an international tax planning scenario
Show steps
Apply your knowledge to a practical scenario and develop a comprehensive tax plan.
Show steps
-
Identify a real-world business scenario involving international operations.
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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.
Organize and review course materials
Show steps
Improve your understanding and retention by organizing and reviewing course materials.
Show steps
Show steps
Show steps
- 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
Show steps
Enhance your understanding by helping others and solidifying your knowledge.
Show steps
Show steps
Show steps
- 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
Show steps
Enhance your understanding of CFCs by creating a structured presentation.
Show steps
Show steps
Show steps
- 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.
One other activity
Expand to see all activities and additional details
Show all four activities
Simulate an international tax planning scenario
Show steps
Apply your knowledge to a practical scenario and develop a comprehensive tax plan.
Show steps
Show steps
Show steps
- 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:
International Tax Accountant
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.
International Tax Lawyer
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.
Transfer Pricing Analyst
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.
International Tax Compliance Manager
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.
Tax Policy Analyst
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.
International Business Consultant
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.
Foreign Exchange Trader
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.
Global Mobility Specialist
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.
Customs Broker
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.
International Development Specialist
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.
Investment Banker
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.
Financial Analyst
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.
Corporate Tax Accountant
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.
Tax Auditor
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.
Forensic Accountant
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.
For more career information including salaries, visit:
OpenCourser.com/course/sm7bza/u
Reading list
We've selected eight books
that we think will supplement your
learning. Use these to
develop background knowledge, enrich your coursework, and gain a
deeper understanding of the topics covered in
U.S. Taxation of International Transactions.
This classic treatise provides an in-depth analysis of U.S. international tax law. It is an essential reference for anyone who works in this area.
Provides a comprehensive overview of international taxation law and policy.
Provides a detailed analysis of the U.S. tax rules applicable to foreign income.
Provides a comprehensive overview of the international tax planning.
Provides a comprehensive overview of the international taxation.
Save
Provides a detailed analysis of the U.S. federal income tax rules that apply to corporations and their shareholders. It valuable resource for practitioners who need to understand the U.S. federal income tax rules that apply to corporations and their shareholders.
Provides an overview of the economics of taxation. It valuable resource for anyone who is interested in the economics of taxation.
Provides an overview of international taxation and transfer pricing. It valuable resource for anyone who is interested in international taxation and transfer pricing.
For more information about how these books relate to this course, visit:
OpenCourser.com/course/sm7bza/u
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Level
Intermediate
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Institution
University of Illinois at Urbana-Champaign
Instructor
Matthew Hutchens
Language
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