COURSE OBJECTIVES: This covers the principles of the US taxation on business activity. Day One focuses on the outbound US taxation, whilst the separately bookable day-two concentrates on inbound taxation.
COURSE CONTENT
General US Tax Concepts
- Classification and Taxation of Entities
- Check-the-Box
- Source of Income
Determination of US Federal Tax Liability
- Book Income vs. Taxable Income
- Tax Rates
- Alternative Minimum Tax
- Consolidated Returns
- Brief overview of State Taxation
- Walkthrough of Form 1120 (US Corporate Tax Return)
Controlled vs. Non-Controlled Foreign Corporations
Distributions of Cash and Property
- Introduction to Earnings and Profits
- Definition of Dividend vs. Return of Capital vs. Capital Gain
- Deemed Distributions
Incorporation of a Company
- General Tax-Free Rules
- Treatment of Boot
- Application of Tax-Free Rules in Multinational Context
Tax-Free Reorganizations
- Overview of Tax-Free Reorganizations
- Overview of Tax Consequences of Tax-Free Reorganizations
- Tax Deferred Share-for-Share Exchanges
- Tax Deferred Asset Acquisitions
Liquidations
- Taxable Liquidations
- Tax-Free Liquidations
- Liquidations in the Outbound Context
WHO SHOULD ATTEND
Those needing a basic background in the US corporate tax system. The course requires delegates to have an understanding of the principles of international taxation.
Would you like this course run in-house? Call us on 0207 566 8207 to find out more
Not quite what you were looking for?
Then please see the following closely related course
Corporate Taxation in the USA - Inbound Taxation