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International Tax Lunch: Claiming Foreign Tax Credit with a Hybrid Entity 4173348A
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The U.S. and foreign countries do not require consistent treatment of business entities: there can be an entity whose income is passed to the owners in a foreign country and is taxed to the entity in the U.S. These types of hybrid entities provide tax planning opportunities for the business owners.

8/11/2017
When: 1:00 PM to 2:00 PM
Where: Webcast
CALCPA
4173348A
United States
Presenter: Haoshen Zhong, JD
Contact: April Deneault
801-466-10300


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Curriculums:   International Business and Corporate Taxation

NASBA Credit Category:  Taxes

CPE Hours:  1

Description

The U.S. and foreign countries do not require consistent treatment of business entities: there can be an entity whose income is passed to the owners in a foreign country and is taxed to the entity in the U.S. These types of hybrid entities provide tax planning opportunities for the business owners.

Materials are provided as an ebook for this course.



Major Subjects

  • Fiscally transparency and opacity
  • Basics of foreign tax credit
  • Basics of S corporation passthrough of income
  • Matching principal under ยง909
  • Passive and general category foreign tax credit

Objectives

  • Recognize the entity classifications a business can choose.
  • Define a hybrid entity.
  • Identify the timing of taking a foreign tax credit.
  • Determine whether a foreign tax is general category or passive category.
  • Determine when a shareholder can take a general category foreign tax credit against dividends.

Level:  Overview

Designed For

CPAs and attorneys.

Advanced Prep:

None.

Prerequisite

None.

Price:

Members: $30

Nonmembers: $50

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