Fundamentals of International Tax
After completing this course, the learner should be able to:
- Recognize key outbound tax provisions—foreign tax credit, foreign-source dividend-received deduction (DRD), PFIC rules, Subpart F regime, transfer pricing, and expatriation rules
- Identify the newer international provisions—Net CFC tested income (NCTI, formerly GILTI), foreign-derived deduction eligible income (FDDEI, formerly FDII), and base erosion and anti-abuse tax (BEAT)
- Recognize key inbound tax provisions—differentiate between business income versus nonbusiness income
- Identify the basics of global tax policy, the countries involved in the OECD, and some of the basic tenets of the OECD’s Pillar One and Pillar Two initiatives
Instructor bio
Tara Fisher has been practicing international tax for more than 20 years. Her professional background includes working for the U.S. Congress Joint Committee on Taxation, the national tax practice of PwC and American University in Washington D.C. During her time with Congress, Tara worked on the Senate Finance Committee's investigation of Enron Corporation and helped draft tax policies that were later adopted as part of the American Jobs Creation Act of 2004. She also assisted the Senate Foreign Relations Committee with the ratification of bilateral income tax treaties, including conventions with the United Kingdom, Japan and Australia. While working for PwC, Tara was stationed abroad in London, where she advised European companies investing in the United States. Tara is a Certified Public Accountant in the states of Pennsylvania and Virginia. She also holds both a Bachelors and Masters degree from the University of Virginia.
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