This course covers classification of nonresident entities for United States tax purposes.
This course covers classification of nonresident entities for United States tax purposes. Coverage begins with classification of organizations as separate from taxpayers, then discusses classification differentiations between trusts and business entities.
This course will cover the following Topics: • Threshold Considerations • Is the Entity a Trust? • Foreign Business Entities • Foreign Business Entities - Entity Classification • Foreign Business Entities - Elections • Foreign Business Entities - Relevance Determinations • Taxation of Foreign Business Entities • Foreign Corporations - Subpart F Income • Foreign Corporations - GILTI • GILTI – Regulatory Guidance • Foreign Corporations - Passive Foreign Investment Companies
Field of Study: Taxes
Lambers, Inc. is a leader in review courses for the EA, AFSP, and CPA exams. Lambers also offers IRS Continuing Education for Tax Preparers and CPE for CPAs. Accounting and finance professionals around the world incorporate Lambers products into their training programs.
J.D., LL.M.
Patrick McCormick is one of the United States’ pre-eminent international tax authorities, publishing his first treatise on nonresident tax in 2021. Patrick is a globally recognized international tax speaker, regularly giving programs to audiences around the world (both in person and virtually) on all aspects of international tax considerations. In 2020 alone, Patrick’s programs on multinational tax issues received more than 100,000 registrations – with the vast majority of those registrants attending multiple programs given by Patrick. In feedback for Patrick’s programs, attendees consistently note that Patrick is their go-to for international tax coursework, in part for his ability to simplify complex international topics.
