As a boutique international tax firm, we’re finding international tax issues arising for individuals and companies of all sizes. Many of them never thought they’d have any cross-border activities. As many of our clients are CPA and law firm across the US, we thought it might be helpful to do a series of discussions on International Tax for the Non-Specialist. They are overviews designed to assist practitioners identify issues. The overview dive into some level of detail, but we envision separate sessions to more fully explain various technicalities.

This discussion is a case study and #2 in the series following: #1 on tax residency and foreign financial account disclosures [FBAR / FinCen 114 / Form 8938]. The primary focus is on a US person being transferred to a foreign affiliate and the important US and foreign tax and non-tax issues that should be addressed, ideally prior to the transfer. This includes, but is not limited to:

  1. The foreign earned income and housing exclusions of Internal Revenue Code Section 911. How does one qualify; what are the benefits; why claiming the exclusions is not always the best answer. Form 2555.
  2. When can the host country tax income and why we care? There is a brief tax treaty discussion.
  3. What is a Secondment agreement?
  4. Does the employee still contribute to (or desire to) a US 401(k) or other retirement plan?
  5. Does the employee still have to file a state tax return in the US?
  6. What about social security?

The presentation begins with an introductory discussion and examples of a US person generating income from outside the US, including a foreign tax credit example and a discussion of Value Added Tax (VAT).

 

Course Key Concept: Foreign earned income and housing exclusions, Section 911, Form 2555, Expat assignment, Secondment VAT, Foreign tax credit, Residency, Green Card, International tax, Global tax, Tax treaty, Certificate of coverage, Bona fide resident, Physical presence test.

Course Series

This course is included in the following series:

7 CoursesPractical International Tax for the Non-Specialist

  1. Practical International Tax for the Non-Specialist #1: Tax Residency and Foreign Financial Account Disclosures
  2. Practical International Tax for the Non-Specialist #2: Case Study - US Person Earning Foreign Income and then Transferred to Foreign Subsidiary.
  3. Practical International Tax for the Non-Specialist #3: Anti-deferral overview - Subpart F and CFCs.
  4. Practical International Tax for the Non-Specialist #4: US Taxation of Nonresident Individuals
  5. Practical International Tax for the Non-Specialist #5: Section 956, Investment of Earnings in US Property
  6. Practical International Tax for the Non-Specialist #6: Check The Box Overview (Entity Classification Election)
  7. Practical International Tax for the Non-Specialist #7: Foreign Investment in US Real Property - FIRPTA
Learning Objectives
  • Explore the non-tax and tax issue a US person faces when transferred to a foreign affiliate company.
  • Identify how a person may qualify to exclude earned income.
  • Discover how the exclusion is reported on Form 2555.
  • Recognize why an advisor must be aware of non-US issues when a US individual is conducting international business.
Last updated/reviewed: August 16, 2023
3 Reviews (30 ratings)

Reviews

5
Anonymous Author
Complicated subject, but some of the basic rules are described clearly. It is also interesting that there is some discussion of other issues that the advisor/tax payer need to look into, beyond what is covered in this course.

5
Member's Profile
Using the case study makes it easy to recall the topics.

5
Member's Profile
Marc's course on international tax was well prepared

Prerequisites
Course Complexity: Intermediate

No advanced preparation or prerequisites are required for this course. However it is recommended to take other Tax courses by Marc Schwartz: Practical International Tax for the Non-Specialist

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 .
Instructor for this course
Course Syllabus
INTRODUCTION AND OVERVIEW
  An Overview of Practical International Tax for the Non-Specialist #2: Case study3:30
  Case Study-Part 16:13
  Case Study-Part 210:15
  Case Study-Part 39:04
  Case Study-Part 47:11
CONTINUOUS PLAY
  Practical International Tax for the Non-Specialist #2: Case study 36:13
SUPPORTING MATERIAL
  Slides: Practical International Tax for the Non-Specialist #2 Case StudyPDF
  Practical International Tax for the Non-Specialist #2 Case Study Glossary/ IndexPDF
REVIEW AND TEST
  REVIEW QUESTIONSquiz
 FINAL EXAMexam