T516 International Taxation II
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T516 International Taxation II
An introduction to the practice of US tax law with respect to the conduct by US persons of business and investment outside the US either directly or through non-US entities. This course seeks to strike a balance between the technical detail within the US tax law and the practical application of that...
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41 епизода
9-01 Foreign Currency Issues
8-01 Tax Treaties – Outbound Aspects
7-01 Non-Recognition Transactions - §367
6-05 Moving IP Overseas Including TP Consequences
6-04 Subpart F and Disregarded Entity Issues
6-03 TP Issues Including Contract Manufacturing and Limited-Risk Distributors
6-02 Functions and Risks
6-01 Bringing It All Together -- Supply Chain Case Study -- Introductory Comments
5-06 The Future
5-05 Recognizing Issues and Managing Risk
5-04 Special Issues
5-03 Transfer Pricing Methods
5-02 Basic Concepts
5-01 Transfer Pricing -- Introduction and Macro View
4-01 PFICs
3-10 §1248
3-09 Special Issues – FBCSI
3-08 Special Issues – FPHCI
3-07 Hopscotch Pattern
3-06 §959 Previously Taxed Income
3-05 §§957 and 958 Definition of CFC
3-04 §956 Investment in US Property
3-03 §954 Foreign Base Company Income
3-02 §§951 and 952 Income Inclusions, US Shareholders, etc
3-01 Subpart F and 1248 -- Introduction
2-08 Effect of Tax Treaties on the FTC
2-07 §904(f) Overall Foreign Loss, etc
2-06 §904(d) Separate FTC Limitation Baskets
2-05 §904 FTC Limitation – Introduction
2-04 Deemed-Paid FTC
2-03 What is a Creditable Tax?
2-02 Who is the Taxpayer and Deduction vs Credit
2-01 Overall Economics of FTC
1-07 Look-Back to International Tax I – Source of Income and Treaties
1-06 Look-Back to International Tax I – Mostly "Check-the-Box"
1-05 Methodology of Tax Practice
1-04 "Big Picture" for this Course
1-03 Case Study Format and "Big-Big Picture"
1-02 Goals - What You'll Understand - Cisco