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International tax

About this topic

Based on the AICPA Competency Framework: Tax and Personal Financial Planning, these learning resources - primarily focused on US tax - are designed to help CPAs understand the knowledge and skills necessary to address the needs of their clients and firms.

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The Authorized OECD Approach to a U.S. Permanent Establishment

This article provides an overview of applying U.S. domestic tax law and a U.S. income tax treaty to a foreign corporation.

Article Treaties Intermediate

New Developments in Outbound Transfers of Intangible Property

​This article updates CPAs about the changes in tax treatment of outbound transfers of goodwill or going concern value to assist clients in planning these transfers.

Article International tax Intermediate

An Update on Foreign Financial Account Reporting

This article revisits the reporting requirements for an FBAR and highlights FBAR reporting requirements that differ from those of Form 8938.

Article FATCA compliance & FBAR reporting Foundational

Issues Involving the Interplay of Subpart F Income Recapture Account and Sec. 956 Inclusion

Treating a Sec. 956 inclusion as not a distribution for purposes of Regs. Sec. 1.952-1(f)(2)(iii) leads to unintended results under certain fact patterns. This article...

Article US anti-deferral rules Intermediate

Foreign Currency Straddles and Transactions Present Complex Tax Issues

With a focus on a foreign currency straddle transaction example, this article discusses the scope and application of Code secs. 1092, 1256, and 988.

Article Income Intermediate

FBAR compliance

This article a detailed overview of the FBAR requirements to help with compliance.

Article FATCA compliance & FBAR reporting Intermediate