Course Information

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U.S. International Taxation: Cross-Border Transfers and Reorganizations
Author: Michael S. Schadewald & Robert J. Misey, Jr.

Description:
This Course addresses the taxation of outbound transfers to, as well as inbound transfer from, foreign corporations is determined under Code Sec. 367. Code Sec. 367 curtails tax-free treatment for many corporate transactions if one or more of the corporations are a foreign corporation, whereas the same transaction would be accorded tax-free treatment if all the parties were U.S. corporations.

The Course will enable the student to determine when Code Sec. 367 applies. If it does, a U.S. taxpayer who transfers property outside the U.S. is treated as though the property were sold to the foreign corporation for fair market value. There are exceptions for transfers of property that would result in a loss, and certain transfers of assets for use in an active foreign business.

The Course will also enable the student to recognize a special branch loss recapture rule that applies when a domestic corporation that has a foreign branch incorporates that branch.

Finally, the Course will enable the student to recognize inbound transfers from a foreign corporation. Just as outbound transfers to foreign corporations are taxed, inbound transfers such as subsidiary liquidations (which would otherwise be tax free if the subsidiary and the parent were U.S. corporations) are taxable events.

Course Details:
Price:  $60.00
Field of Study:  Taxes
Prerequisites:  U.S. International Taxation: Anti-Avoidance Regimes, or equivalent knowledge.
Level:  Basic
CTEC course number:  1075-CE-6155
Course was last updated on:  06/28/2010
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Library:
U. S. International Taxation

Technical Requirements:
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Credit Available For: Units
CFP (Accepted by the CFP Board) 5.00 CPE
CPE 5.00 CPE
CTEC Federal 5.00 CE
Enrolled Agent (Accepted by the IRS) 5.00 CPE
National Registry Interactive 5.00 CPE
National Registry New Standards 5.00 CPE
QAS 5.00 CPE

Note: Recommended CPE credit is based on a 50-minute hour. Participants earning credits for states that require self-study to be based on a 100-minute hour will receive half the recommended CPE credits for successful completion of this course.

Since Continuing Professional Education requirements vary from state to state and are subject to change without notice, please contact your state board of accountancy for information on your CPE requirements and the applicability of this course to meet those specifications.

CCH has been approved by the California Tax Education Council to offer courses that provide federal and state credit towards the annual "continuing education" requirement imposed by the State of California. A listing of additional requirements to register as a tax preparer may be obtained by contacting CTEC at P.O. Box 2890, Sacramento, CA, 95812-2890, toll-free by phone at (877) 850-2832, or on the Internet at www.ctec.org.