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.

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.

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.