Understand and discuss:
1. The U.S. tax policy implications dealing with both outboudn and inbound transactions.
2. The impact U.S. tax law has on international business.
3. The relationship and application of Income Tax Treaties
4. Issues dealing with intercompany pricing between controlled entities.
Apply skills involving the U.S. taxation of multinational commerce, including:
1. Identify icome source and allocation and apportionment of deductions.
2. Calculate a taxpayer's direct and deemed paid foreign tax credit.
3. Identify taxpayers who are eligible for hte foreign earned income exclusion and calculate the amount of hte exclusion.
4. Identify a controlled foreign corporation (CFC) and compute the CFC's subpart F income and the deemed distribution that flows through to the U.S. shareholders.
5. Understand and apply the rules dealing with foreign taxpayers earning income and oding business in the U.S.