he AICPA U.S. International Tax Certificate Program provides the knowledge you need to navigate the ever-changing international tax landscape effectively. The courses are updated with the latest guidance from the IRS, including regulations and notices on Foreign Tax Credit (FTC), Global Intangible Low-Taxed Income (GILTI) and Base Erosion and Anti-Abuse Tax (BEAT).

The Learners go through three certifications as under. Once the learners complete each of these certifications, they get a digital badge for the same

U.S. International Tax: Core Concepts

Earners of the U.S. International Tax: Core Concepts badge demonstrate knowledge of core international taxation concepts. These candidates apply their expertise to global tax system transactions by identifying and using critical impacts of the Tax Cuts and Jobs Act (TCJA) on international transactions such as transfer pricing, income sourcing, and foreign tax credits.

Learning objectives

• Distinguish the differences between various types of global tax systems and certain characteristics of each
• Recognize the choice of entity considerations
• Recognize U.S. income sourcing rules
• Identify the basic principles of inbound and outbound taxation and identify transactions that generate tax issues for each
• Recognize how the Tax Cuts and Jobs Act has impacted international taxation

U.S. International Tax: Inbound and Outbound Transactions

This certification course is designed to help tax professionals better navigate the ever-changing international tax landscape. Learners demonstrate knowledge of inbound and outbound taxation, including the major US international tax reform areas such as DRD, GILTI, BEAT, FDII, and Section 965. They’ve also learned such inbound topics as effectively connected income, sourcing, withholding rules, FATCA and compliance.

Learning objectives

• Determine U.S. shareholder and CFC status under the new rules from tax reform
• Recognize the operating rules of subpart F income
• Recognize the Foreign Tax Credit Rules and key concepts
• Identify issues related to dual consolidated losses, foreign currency rules and regimes under U.S. tax law
• Identify detailed rules covering sourcing, withholding and compliance issues

U.S. International Tax: Advanced Issues

Demonstrates knowledge of advanced international tax issues and transactions, such as U.S. transfer pricing, tax treaties, global BEPS, reorganizations, stock acquisitions, inversion rules and more.

Learning objectives

• Identify the accepted transfer pricing methods  for cross border transactions and when it’s appropriate to use them
• Recall how U.S tax treaties determine U.S tax residency and how it impacts eligibility under the treaty
• Distinguish how hybrid entities are treated under U.S. income tax treaties
• Assess whether a U.S. person’s transfer of property to a foreign corporation should generally qualify for non-recognition treatment under section 351
• Assess whether a reorganization or restructuring may qualify as an “inversion” subject to the rules of section 7874

Who should take this?

• CPAs or consultants serving U.S.-based multinational companies.
• Accounting & finance staff, including CPAs, in business & industry seeking to understand international tax concepts to make more informed business decisions.
• Public accounting firms with clients who are global or planning on becoming global seeking to understand the complex and dynamic international tax environment.

 

Course outline

CPE Credits	50.5
Prerequisite	It is recommended that you complete each certificate in sequential order as the content presented in each certificate builds on training in previous certificates.
Format:	Course materials  - Online. US Taxation course
Access:	This is a digital product. You will have access to the content for 2 years after purchase date.