Author : | Andrew Clark, EA |
Course Length : | Pages: 48 ||| Review Questions: 24 ||| Final Exam Questions: 40 |
CPE Credits : | 8.0 |
IRS Credits : | 8 |
Price : | $71.95 |
Passing Score : | 70% |
Course Type: | NASBA QAS - Text - Technical - NASBA Registry - IRS Enrolled Agents |
Primary Subject-Field Of Study: | Taxes - Taxes for Course Id 1425 |
Description : | The Tax Cuts and Jobs Act will dramatically change the US tax code in 2018. The Tax Cuts and Jobs Act is organized into four primary sections of: Individual Tax Reform, Business Tax Reform, Exempt Organizations and International Provisions. This course will provide a thorough review of the International Provisions portion of the Tax Cuts and Jobs Act Bill (H.R.1.). Part 1 of this course will provide a summary description of all provisions referenced in the International Provisions section of the Tax Cuts and Jobs Act. It will identify which sections changed and which remained the same. Each provision will reference a more detailed description of the provision in Part 2 of this course. The detailed description will review the current law, provide a detailed description of the change and identify the effective date that the provision will become effective. |
Usage Rank : | 0 |
Release : | 2018 |
Version : | 1.0 |
Prerequisites : | Basic understanding of federal tax code. |
Experience Level : | Overview |
Additional Contents : | Complete, no additional material needed. |
Additional Links : |
ax Cuts and Jobs Act - International Tax Update
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Advance Preparation : | None. |
Delivery Method : | QAS Self Study |
Intended Participants : | Anyone needing Continuing Professional Education (CPE). |
Revision Date : | 25-Oct-2019 |
NASBA Course Declaration : | Participants must complete the final examination within one year of purchase and with a minimum passing grade of 70% or better to receive CPE credit unless otherwise noted on the Course History page (i.e. California Ethics must score 90% or better). After logging in click on the Course History links on your My Courses page for the Begin date and Expire date for the Final Exam. |
Approved Audience : | NASBA QAS - Text - Technical - NASBA Registry - IRS Enrolled Agents - 1425 |
Keywords : | Taxes, Tax, Cuts, Jobs, Act, International, Tax, Provisions, For, 2018, Tax, Year, cpe, cpa, online course |
Learning Objectives : |
Course Learning Objectives At the end of this course, students will be able to:
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Course Contents : | Chapter 1 - Tax Cuts and Jobs Act - International Tax Provisions Course Learning Objectives Introduction Part 1 - Overview of the Tax Cuts and Jobs Act INTERNATIONAL TAX PROVISIONS Establishment of Participation Exemption System for Taxation of Foreign Income Deduction for foreign-source portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations Modification of subpart F inclusion for increased investments in United States property Special rules relating to sales or transfers involving specified 10-percent owned foreign corporations Treatment of deferred foreign income upon transition to participation exemption system of taxation and deemed repatriation at two-tier rate Election to increase percentage of domestic taxable income offset by overall domestic loss treated as foreign source Rules Related to Passive and Mobile Income Deduction for foreign-derived intangible income and global intangible low-taxed income Special rules for transfers of intangible property from controlled foreign corporations to United States shareholders Modifications Related to Foreign Tax Credit System Repeal of section 902 indirect foreign tax credits; determination of section 960 credit on current year basis Source of income from sales of inventory determined solely on basis of production activities Separate foreign tax credit limitation basket for foreign branch income Acceleration of election to allocate interest, etc., on a worldwide basis Modification of Subpart F Provisions Repeal of inclusion based on withdrawal of previously excluded subpart F income from qualified investment Repeal of treatment of foreign base company oil related income as subpart F income Inflation adjustment of de minimis exception for foreign base company income Look-thru rule for related controlled foreign corporations made permanent Modification of stock attribution rules for determining CFC status Modification of definition of United States shareholder Elimination of requirement that corporation must be controlled for 30 days before subpart F inclusions apply Current year inclusion of foreign high return amounts or global intangible low-taxed income by United States shareholders Prevention of Base Erosion Base erosion using deductible cross-border payments between affiliated companies Limitations on income shifting through intangible property transfers Certain related party amounts paid or accrued in hybrid transactions or with hybrid entities Shareholders of surrogate foreign corporations not eligible not eligible for reduced rate on dividends Provisions Related to the Possessions of the United States Extension of deduction allowable with respect to income attributable to domestic production activities in Puerto Rico Extension of temporary increase in limit on cover over of rum excise taxes to Puerto Rico and the Virgin Islands Extension of American Samoa economic development credit Other International Reforms Restriction on insurance business exception to the passive foreign investment company rules Repeal of fair market value of interest expense apportionment Modification to source rules involving possessions Part 1 - Review Questions Part 2 - Detailed Information and Present Law INTERNATIONAL TAX PROVISIONS A. Establishment of Participation Exemption System for Taxation of Foreign Income 1. Deduction for foreign-source portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations 2. Modification of subpart F inclusion for increased investments in United States property 3. Special rules relating to sales or transfers involving specified 10-percent owned foreign corporations 4. Treatment of deferred foreign income upon transition to participation exemption system of taxation and deemed repatriation at two-tier rate 5. Election to increase percentage of domestic taxable income offset by overall domestic loss treated as foreign source B. Rules Related to Passive and Mobile Income 1. Deduction for foreign-derived intangible income and global intangible low-taxed income 2. Special rules for transfers of intangible property from controlled foreign corporations to United States shareholders C. Modifications Related to Foreign Tax Credit System 2. Source of income from sales of inventory determined solely on basis of production activities. 75 3. Separate foreign tax credit limitation basket for foreign branch income 4. Acceleration of election to allocate interest, etc., on a worldwide basis D. Modification of Subpart F Provisions 1. Repeal of inclusion based on withdrawal of previously excluded subpart F income from qualified investment 2. Repeal of treatment of foreign base company oil related income as subpart F income 3. Inflation adjustment of de minimis exception for foreign base company income 4. Look-thru rule for related controlled foreign corporations made permanent 5. Modification of stock attribution rules for determining CFC status 6. Modification of definition of United States shareholder 7. Elimination of requirement that corporation must be controlled for 30 days before subpart F inclusions apply 8. Current year inclusion of foreign high return amounts or global intangible low-taxed income by United States shareholders Part 2a - Review Questions 9. Limitation on deduction of interest by domestic corporations which are members of an international group E. Prevention of Base Erosion 1. Base erosion using deductible cross-border payments between affiliated companies 2. Limitations on income shifting through intangible property transfers 3. Certain related party amounts paid or accrued in hybrid transactions or with hybrid entities 4. Shareholders of surrogate foreign corporations not eligible not eligible for reduced rate on dividends F. Provisions Related to the Possessions of the United States 1. Extension of deduction allowable with respect to income attributable to domestic production activities in Puerto Rico 2. Extension of temporary increase in limit on cover over of rum excise taxes to Puerto Rico and the Virgin Islands 3. Extension of American Samoa economic development credit G. Other International Reforms 1. Restriction on insurance business exception to the passive foreign investment company rules 2. Repeal of fair market value of interest expense apportionment 3. Modification to source rules involving possessions Part 2b - Review Questions Glossary |