Focus on the Principles Relating to the Taxation of Foreign Persons and Income
This basic seminar in international taxation will focus on the principles relating to the U.S. taxation of foreign persons (individuals as well as legal entities) and the U.S. taxation of income received by U.S. individuals and entities from activities abroad. Topics will include principles of international tax jurisdiction; rules relating to the source of income and deductions; the foreign tax credit; Section 482 and transfer pricing; an introduction to controlled foreign corporations; and international double taxation treaties. The seminar will then focus on current developments including FATCA and international tax reform proposals.
- Identify selected key elements in the U.S. tax treatment of:
- U.S. Corporations & Individuals with Foreign Operations, Assets or Income
- Foreign Corporations & Individuals with U.S. Income
- FATCA & Other Current Developments Affecting U.S. Taxation of Foreign Income & Foreign Persons
Number of Units: The University of San Diego School of Law is a State Bar of California-approved provider of MCLE credit and certifies that this event is approved for 4.0 hours of general credit.
Who Should Attend: Tax attorneys, CPA’s, Enrolled Agents, or any individual responsible for managing or overseeing a firm’s tax practice.
Instructor: John I. Forry, JD, is Director of U.S. Law Program for International Legal Professionals and Professor-in-Residence, University of San Diego School of Law. John currently divides his academic efforts among five U.S. and European law and business schools, as well as counseling private clients on international activities. He has served on the Advisory Group to the U.S. Commissioner of Internal Revenue and on numerous bar-related committees and projects. He has authored or co-authored five books and over 40 articles on international taxation, finance and investment.