Assignment : International Taxation and Foreign Tax Credits

Assume you are a CPA employed as an international tax consultant hired to provide advice to a U.S.-based client expanding operations into foreign markets.

Using the Internet or Strayer Learning Resource Center, conduct research on the tax impacts for U.S. companies expanding into foreign markets.

Write a four to six (4-6) page paper in which you:

Based on your research, analyze the major impact of using a controlled foreign corporation to expand abroad. Examine two (2) methods you would recommend to the client to circumvent the provisions of subpart F to reduce the client's tax liability. Provide at least two (2) examples to support your recommendations.

Based on your research, create a plan for the client to take advantage of lower taxes by shifting profits to the tax havens or lower tax countries instead of shifting investments to these countries. Provide a rationale to support your plan.

Develop a strategy for the client to convert passive income into active income deferring immediate U.S. taxation until repatriated home based on your research. Provide support for your recommendation.

Analyze the available foreign tax credits to your client. Propose at least three (3) tax credits the client could use and the impact of the credits on other foreign loss income. Provide examples to support your recommendations.

Use at least four (4) quality resources in this assignment. Note: Wikipedia and similar Websites do not qualify as quality resources.

Format your assignment according to the following formatting requirements:

Typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides.

Include a cover page containing the title of the assignment, the students name, the professors name, the course title, and the date. The cover page is not included in the required page length.

Include a reference page. Citations and references must follow APA format. The reference page is not included in the required page length.

The specific course learning outcomes associated with this assignment are:

Analyze the legal basis of outbound international taxation and foreign tax credit limitations.

Determine the tax implications of conducting business in non-U.S. currencies.

Examine direct investments abroad through a foreign branch or foreign company.

Use technology and information resources to research issues in international tax planning and research.

Write clearly and concisely about international tax planning and research using proper writing mechanics