T516 International Taxation II

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

1-01 Intro to Course Including Admin Matters

1-01 Intro to Course Including Admin Matters

10-13
17:55

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

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

10-13
26:39

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

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

10-13
44:53

1-04 "Big Picture" for this Course

1-04 "Big Picture" for this Course

10-13
12:18

1-05 Methodology of Tax Practice

1-05 Methodology of Tax Practice

10-13
15:10

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

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

10-13
01:07:26

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

10-13
13:26

2-01 Overall Economics of FTC

2-01 Overall Economics of FTC

10-13
18:55

2-02 Who is the Taxpayer and Deduction vs Credit

2-02 Who is the Taxpayer and Deduction vs Credit

10-13
01:07:45

2-03 What is a Creditable Tax?

2-03 What is a Creditable Tax?

10-13
38:27

2-04 Deemed-Paid FTC

2-04 Deemed-Paid FTC

10-13
40:17

2-05 §904 FTC Limitation – Introduction

2-05 §904 FTC Limitation – Introduction

10-13
34:43

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

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

10-13
53:44

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

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

10-13
26:15

2-08 Effect of Tax Treaties on the FTC

2-08 Effect of Tax Treaties on the FTC

10-13
14:47

3-01 Subpart F and 1248 -- Introduction

3-01 Subpart F and 1248 -- Introduction

10-13
01:05:59

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

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

10-13
28:28

3-03 §954 Foreign Base Company Income

3-03 §954 Foreign Base Company Income

10-13
01:03:42

3-04 §956 Investment in US Property

3-04 §956 Investment in US Property

10-13
14:06

3-05 §§957 and 958 Definition of CFC

3-05 §§957 and 958 Definition of CFC

10-13
34:16

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