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International Tax: Basics of Income Sourcing

Author: Patrick McCormick

CPE Credit:  2 hours for CPAs

This course provides an overview of income sourcing rules maintained by the United States. Sourcing rules are critical for non-residents, who are almost exclusively taxed by the United States on income directly sourced to the country. Sourcing has become increasingly important for American taxpayers—particularly corporate ones, who qualify for significant deductions on foreign-sourced income. This course provides background on how sourcing determinations are made, including allocating income items between different income categories. The course will also cover special rules in the sourcing context—specifically, those related to multi-year compensation arrangements.

Publication Date: February 2023

Topics Covered

  • How sourcing determinations are made
  • Special rules in the sourcing context

Learning Objectives

  • Explain how Foreign-Derived Intangible Income (FDII) applies to corporations
  • Identify the scope of United States tax rules for non-residents
  • Identify income sourcing rules across various situations

Level
Overview

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None

Registration Options
Quantity
Fees
Regular Fee $67.00

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