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T516 International Taxation II
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T516 International Taxation II

Author: Jeffery Kadet

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© Jeffery Kadet

Description

An introduction to the practice of US tax law with respect to the conduct by US persons of business and investment outside the US either directly or through non-US entities. This course seeks to strike a balance between the technical detail within the US tax law and the practical application of that law to typical business and investment situations. The goals of the course include: -Achieving familiarity and understanding of the provisions of US tax law relevant to "outbound" investment -Developing skill in applying these provisions of US law to practical business and investment situations Developing an ability to examine an outbound business or investment situation and to identify relevant US tax issues -Learning to analyze the various US issues in order to arrive at conclusions and recommended courses of action, -Developing sensitivity to identify opportunities and risks Contents of Class Sessions
40 Episodes
Reverse
1-01 Intro to Course Including Admin Matters

1-01 Intro to Course Including Admin Matters

2011-10-1317:55

1-01 Intro to Course Including Admin Matters
1-02 Goals - What You'll Understand - Cisco

1-02 Goals - What You'll Understand - Cisco

2011-10-1326:39

1-02 Goals - What You'll Understand - Cisco
1-03 Case Study Format and "Big-Big Picture"

1-03 Case Study Format and "Big-Big Picture"

2011-10-1344:53

1-03 Case Study Format and "Big-Big Picture"
1-04 "Big Picture" for this Course

1-04 "Big Picture" for this Course

2011-10-1312:18

1-04 "Big Picture" for this Course
1-05 Methodology of Tax Practice

1-05 Methodology of Tax Practice

2011-10-1315:10

1-05 Methodology of Tax Practice
1-06 Look-Back to International Tax I – Mostly "Check-the-Box"

1-06 Look-Back to International Tax I – Mostly "Check-the-Box"

2011-10-1301:07:26

1-06 Look-Back to International Tax I – Mostly "Check-the-Box"
1-07 Look-Back to International Tax I – Source of Income and Treaties

1-07 Look-Back to International Tax I – Source of Income and Treaties

2011-10-1313:26

1-07 Look-Back to International Tax I – Source of Income and Treaties
2-01 Overall Economics of FTC

2-01 Overall Economics of FTC

2011-10-1318:55

2-01 Overall Economics of FTC
2-02 Who is the Taxpayer and Deduction vs Credit

2-02 Who is the Taxpayer and Deduction vs Credit

2011-10-1301:07:45

2-02 Who is the Taxpayer and Deduction vs Credit
2-03 What is a Creditable Tax?

2-03 What is a Creditable Tax?

2011-10-1338:27

2-03 What is a Creditable Tax?
2-04 Deemed-Paid FTC

2-04 Deemed-Paid FTC

2011-10-1340:17

2-04 Deemed-Paid FTC
2-05 §904 FTC Limitation – Introduction

2-05 §904 FTC Limitation – Introduction

2011-10-1334:43

2-05 §904 FTC Limitation – Introduction
2-06 §904(d) Separate FTC Limitation Baskets

2-06 §904(d) Separate FTC Limitation Baskets

2011-10-1353:44

2-06 §904(d) Separate FTC Limitation Baskets
2-07 §904(f) Overall Foreign Loss, etc

2-07 §904(f) Overall Foreign Loss, etc

2011-10-1326:15

2-07 §904(f) Overall Foreign Loss, etc
2-08 Effect of Tax Treaties on the FTC

2-08 Effect of Tax Treaties on the FTC

2011-10-1314:47

2-08 Effect of Tax Treaties on the FTC
3-01 Subpart F and 1248 -- Introduction

3-01 Subpart F and 1248 -- Introduction

2011-10-1301:05:59

3-01 Subpart F and 1248 -- Introduction
3-02 §§951 and 952 Income Inclusions, US Shareholders, etc

3-02 §§951 and 952 Income Inclusions, US Shareholders, etc

2011-10-1328:28

3-02 §§951 and 952 Income Inclusions, US Shareholders, etc.
3-03 §954 Foreign Base Company Income

3-03 §954 Foreign Base Company Income

2011-10-1301:03:42

3-03 §954 Foreign Base Company Income
3-04 §956 Investment in US Property

3-04 §956 Investment in US Property

2011-10-1314:06

3-04 §956 Investment in US Property
3-05 §§957 and 958 Definition of CFC

3-05 §§957 and 958 Definition of CFC

2011-10-1334:16

3-05 §§957 and 958 Definition of CFC
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