AICPA logo
Cart
searchSearch
search
burger
AICPA logo
  • Home
product-image
Taxation of Income Earned by Foreign Subsidiaries
CPE Self-study

Taxation of Income Earned by Foreign Subsidiaries

This CPE self-study course focuses on determining US shareholder and CFC status under the new rules from tax reform.

$108 - $175
Do you have an AICPA membership? Log in to apply your member discount.

Format

Online

NASBA Field of Study

Taxes

Level

Basic

CPE Credits

7

Author(s)

Farid Khosravi, Eric Gabbai, David Zaiken, Christopher Summer, Kyle Brandon

Availability

1 year

Product Number

189350

 Business & partner 
Product Details

Differ from the "old" rules.

This self-study online course is part of the U.S. International Tax Certificate, a comprehensive learning program geared to help global finance and accounting professionals navigate the highly complex world of international taxation. This course can be purchased individually or as part of the U.S.International Tax: Inbound and Outbound Transactions bundle. You must purchase the bundle to earn the digital badge.

This CPE self-study course focuses on determining U.S. shareholder and Controlled Foreign Corporation (CFC) status under the new rules from tax reform. There is also discussion on how such rules differ from the "old" rules.

The course also provides a detailed session on the operating rules of subpart F income but not including section 956 and Global Intangible Low-Taxed Income (GILTI) inclusions. There is detailed discussion on international topics regarding calculating and reporting E&P for U.S. federal income tax purposes, as well as practical examples and application.

Also discussed in detail are international topics regarding Passive Foreign Investment Companies (PFICs) and foreign asset reporting for U.S. federal income tax purposes, as well as practical examples and application.

Key Topics
  • Determination of CFC and U.S. Shareholders
  • Application of constructive ownership rules
  • New downward attribution
  • Section 962
  • All forms of subpart F income (FPHCI, sales, and services)
  • Operating rules
  • Exceptions
  • Why is E&P Important
  • Overview of the E&P Computation
  • Common E&P Adjustments
  • Applying E&P to Your Clients: What to look for and real-world examples
  • Reporting E&P on Form 5471
  • Tax issues resulting from E&P issues
  • Definition of a PFIC and Examples
  • Shareholder Taxation of PFICs without QEFs
  • Shareholder Taxation of PFICs with QEFs
  • Mark-to-market Elections (Mark-to-market 1296)
  • Retroactive Relief
  • Foreign Asset Reporting Requirements
  • Excess Distribution 1291
  • Qualified Electing Funds 1293 & 1295
  • FBARs and 8938s
Learning Outcomes
  • Identify a CFC and a U.S. shareholder
  • Apply constructive stock attribution rules properly (*Tax reform)
  • Distinguish how rules around indirect and direct ownership is applied
  • Section 962 Elections
  • Differentiate the different types of subpart F income
  • Identify situations that would create subpart F income for a U.S. entity
  • Calculate subpart F income for specific scenarios
  • Apply specific rules providing exceptions and limitations for subpart F income
  • Identify the importance of E&P in an International Context
  • Recall E&P
  • Calculate Common E&P Adjustments
  • Apply E&P Concepts to common International Tax transactions
  • Determine when you have PFICs
  • Recognize the consequences of PFIC ownership
  • Differentiate the tax implications of PFIC elections
  • Recall PFIC reporting
  • Recognize Foreign Asset reporting requirements beyond PFIC
Credit Info
CPE Credits
Online
7
NASBA Field of Study
Taxes
Level
Basic
Prerequisites
None
Access
Online
This is a digital product. You will have access to the content for 1 year after purchase date.
Pricing
Do you have an AICPA membership? Log in to apply your member discount.
Nonmembers
Online
$175.00
AICPA Members
Online
$135.00
Tax Section Members
Online
$108.00

Group ordering for your team

2 to 5 registrants

Save time with our group order form. We’ll send a consolidated invoice to keep your learning expenses organized.

Start order

6+ registrants

We can help with group discounts. Call us at 1-800-634-6780 (option 1) or email us at salessupport@aicpa.org

Contact us
Instructors
Farid Khosravi
Eric Gabbai
David Zaiken
Christopher Summer
Kyle Brandon
CPA
Kyle is a Senior Manager in the International tax practice with Grant Thornton’s Minneapolis office. He has over eight years of experience providing international tax services to public and privately held businesses. Kyle leads Grant Thornton’s U.S. export tax incentives group. He is involved in the planning and execution of U.S. export opportunities for qualifying companies throughout Grant Thornton’s US firm.
Accessibility

The Association is dedicated to removing barriers to the accountancy profession and ensuring that all accountancy professionals and other members of the public with an interest in the profession or joining the profession, including those with disabilities, have access to the profession and the Association's website, educational materials, products, and services. The Association is committed to making professional learning accessible to all. This commitment is maintained in accordance with applicable law. For additional information, please refer to the Association's Website Accessibility Policy. For accommodation requests, please contact adaaccessibility@aicpa-cima.com and indicate the product that you are interested in (title, etc.) and the requested accommodation(s): Audio/Visual/Other. A member of our team will be in contact with you promptly to make sure we meet your needs appropriately.

Shipping and delivery
Shipping costs  and sales taxes will be added later during checkout
Cancellation Policy
View our Cancellation policy here
Taxation of Income Earned by Foreign Subsidiaries
Select from the following options:
Online
$175.00
Nonmember Price
$175.00
Price excluding sales tax
$175.00
Do you have an AICPA membership? 
Log in to apply your member discount.
Shipping cost and sales tax will be added later during checkout

Related content