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Patrick McCormick, 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.
Not currently accepting new students
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 covers 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
Learning Objectives
- Identify the classification of nonresident entities for United States tax purposes.
- Explore the classification of organizations as separate from taxpayers.
- Recognize the classification differentiations between trusts and business entities.
Last updated/reviewed: January 16, 2022
Prerequisites
Course Complexity: Foundational
No advanced preparation or prerequisites are required for this course.
Education Provider Information
Company:
Illumeo, Inc., 75 East Santa Clara St., Suite 1215, San Jose, CA 95113
Contact:
For more information regarding this course, including complaint and cancellation policies, please contact our offices at (408) 400- 3993 or send an e-mail to .