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Preview: ACC568 : International Tax Planning and Research
Course Guide
Prerequisites
Course Description
Instructional Materials
Course Resources
Course Learning Outcomes
This
course provides a comprehensive overview of the tax systems of key European, Asian, African, South American, and Central American countries,
as well as Canada. It examines the various complex issues in partnership and corporate tax planning, and the tax issues involved with joint ventures
and consolidated returns filed in the United States.
Required Resources
Mindy Herzfeld. 2020. International
Taxation
in
a
Nutshell (12th ed.). West Academic Publishing.
Internal Revenue Service. No date. https://www.irs.gov/
Supplemental Resources
Jim Alajbegu. 2016.
State and Local Tax Considerations for Inbound Foreign Entities. Tax
Adviser, vol. 47, no.10, pp. 68–70.
http://libdatab.strayer.edu/login?url=https://search.ebscohost.com/login.aspx?direct=true&db=bth&AN=118532225&site=eds-live&scope=site
Mark
Heroux. October 1, 2018.
Cryptocurrency: Compliance Challenges and IRS Enforcement. Tax
Adviser, pp. 1–6. http://libdatab.strayer.edu/login?
url=https://search.ebscohost.com/login.aspx?direct=true&db=bth&AN=132130185&site=eds-live&scope=site
Alistair Nevius. June 1, 2017.
Amazon Wins Multimillion-Dollar Transfer-Pricing Dispute With IRS. Journal
of
Accountancy.
https://www.journalofaccountancy.com/issues/2017/jun/amazon-wins-transfer-pricing-dispute-with-irs.html
Sally
Schreiber. June 30, 2016.
Final Rules Govern U.S. Country-by-Country Reporting. Journal
of
Accountancy.
https://www.journalofaccountancy.com/news/2016/jun/irs-rules-country-by-country-reporting-201614765.html#sthash.KOAj1i27.dpuf
Sally
Schreiber. September 14, 2018.
IRS Issues Proposed Regs. for GILTI Inclusions. Journal
of
Accountancy.
https://www.journalofaccountancy.com/news/2018/sep/irs-regs-gilti-inclusions-201819719.html
Sally
Schreiber. August 1, 2018.
Proposed Regs. Address Several Transition Tax issues. Journal
of
Accountancy.
https://www.journalofaccountancy.com/news/2018/aug/irs-regulations-transition-tax.html
Scott
Spencer. January 31, 2012.
Three Common Currency-Adjustment Pitfalls. Journal
of
Accountancy.
https://www.journalofaccountancy.com/Issues/2012/Feb/20113891.html
Create a proposal for implementing strategies that reduce the U.S. tax impact of foreign sourced income.
1
Analyze the tax advantages and disadvantages of conducting business in the U.S. for a foreign capital investor
seeking to maximize available tax benefits.
2
Develop a plan to reduce tax liability, lower taxes, neutralize the impact of the Tax Cuts and Jobs Act, and use tax
credits for a U.S.-based company that has expanded into foreign markets.
3
4
NOTE: The links in this document do not function. Please refer to your online course to view/download linked content.
Weekly Course Schedule
Week 1 - To Do List
Discuss: Introduce yourself to your classmates and professor.
Learn: Read Chapter 1, "Introduction," from International
Taxation
in
a
Nutshell.
Learn: Read Chapter 2, “Basic U.S. Jurisdictional Tax Principles,” from International
Taxation
in
a
Nutshell.
Discuss: Complete the discussion, Is International Taxation Really Necessary?
Week 2 - To Do List
Learn: Read Chapter 3, "Source Rules," from International
Taxation
in
a
Nutshell.
Discuss: Complete the discussion, Why Not Have One International Tax to Prevent Manipulation by Tax Advisors?
Assignment: Submit the assignment, Foreign Source Income Rules (Client Letter).
Week 3 - To Do List
Learn: Read Chapter 4, “Taxing Rules for Non-U.S. Persons,” from International
Taxation
in
a
Nutshell.
Learn: Review the supplemental article, “Proposed Regs. Address Several Transition Tax Issues."
Discuss: Complete the discussion, Foreign Taxpayers Conducting Business in the United States.
Week 4 - To Do List
Learn: Read Chapter 5, “The Role of Income Tax Treaties," from International
Taxation
in
a
Nutshell.
Learn: Read Chapter 6, “Filing, Withholding, and Reporting Requirements," from International
Taxation
in
a
Nutshell.
Discuss: Complete the discussion, The Role of Treaties on International Tax Transactions.
Assignment: Submit the assignment, Foreign Taxpayers Engaged in a Trade or Business in the United States.
Week 5 - To Do List
Create a proposal for allocating revenues and costs that satisfies IRS codes while determining the lowest possible
taxes for a multinational company that engages in cross border transactions in two foreign countries.
Week 5 - To Do List
Learn: Read Chapter 7, “Introduction to U.S. Business Activity in Foreign Countries," from International
Taxation
in
a
Nutshell.
Learn: Read Chapter 9, "Taxation of U.S. Persons' Foreign Income Earned in Corporate Form," from International
Taxation
in
a
Nutshell.
Learn: Review the supplemental article, “IRS Issues Proposed Regs. for GILTI Inclusions.”
Discuss: Complete the discussion, The Importance of Controlled Foreign Corporations.
Week 6 - To Do List
Learn: Read Chapter 8, "Introduction to the Foreign Tax Credit," from International
Taxation
in
a
Nutshell.
Learn: Read Chapter 10, "Limitations on the Foreign Tax Credit and the Indirect Credit," from International
Taxation
in
a
Nutshell.
Learn: Review the supplemental article, “Final Rules Govern U.S. Country-by-Country Reporting.”
Discuss: Complete the discussion, Managing Foreign Tax Credits.
Week 7 - To Do List
Learn: Read Chapter 11, "Intercompany Pricing," from International
Taxation
in
a
Nutshell.
Learn: Review the supplemental article, “Amazon Wins Multimillion-Dollar Transfer-Pricing Dispute With IRS."
Discuss: Complete the discussion, Transfer Pricing.
Week 8 - To Do List
Learn: Read Chapter 12, “Foreign Currency," from International
Taxation
in
a
Nutshell.
Learn: Read Chapter 13, “International Tax-Free Transactions," from International
Taxation
in
a
Nutshell.
Learn: Review the supplemental article, “Three Common Currency-Adjustment Pitfalls: How to Correctly Account for Foreign-Currency Translations."
Discuss: Complete the discussion, Foreign Tax Currency and Transfer of Property to Foreign Corporations.
Assignment: Complete the assignment, International Taxation and Foreign Tax Credits.
Week 9 - To Do List
Week 9 - To Do List
Learn: Read Chapter 14, "Tax Arbitrage and an Evolving Global Tax Landscape," from International
Taxation
in
a
Nutshell.
Discuss: Complete the discussion, Tax Arbitrage and Economic Substance.
Week 10 - To Do List
Learn: Read Chapter 15, "Tax and Trade and Foreign Policy," from International
Taxation
in
a
Nutshell.
Discuss: Complete the discussion, International Boycott and Foreign Bribery Payments.
Assignment: Submit the assignment, Intercompany Pricing.
Week 11 - To Do List
Discuss: Complete the discussion, Using What You’ve Learned.
Grading Scale
Participation Total Points % of Grade
Discussion Participation 330 33%
Assignment Total Points % of Grade
w02a1 - Foreign Source Income Rules (Client Letter) 125 12.5 %
w04a1 - Foreign Taxpayers Engaged in a Trade or Business in the United States 150 15 %
w08a1 - International Taxation and Foreign Tax Credits 175 17.5 %
w10a1 - Intercompany Pricing 220 22 %
Totals 1000 100%
Final Course Grade
Points Percentage Grade
900 - 1000
90% - 100% A
800 - 899
80% - 89% B
700 - 799
70% - 79% C
699
69% and below F
Unique Course Features
Assignments
w10a1 - Intercompany Pricing
Summary
Click the linked activity title to access the assignment.
Text
Overview
Transfer pricing is important to multinational entities and tax administrators. Transfer pricing involves transactions between affiliated entities domiciled
in different countries creating different tax requirements. Profit determination of multinationals generated by intra-company transactions is one of the
most challenging issues in international taxation.
For this assignment, identify a multinational company that engages in cross border transactions in two foreign countries. Suppose that this company
has engaged you to provide advice on intercompany pricing to achieve the lowest combined taxes for all jurisdictions.
Instructions
Using the Internet and/or Strayer Library, research the rules and techniques for transfer pricing. Choose two foreign countries and research their
respective tax rates.
Write a 5–7-page paper in which you:
1. Provide the name of the company you’ve selected and what type of international business they are engaged in. Based on your research, create
projections of revenues, costs, and tax rates based on the company’s transaction in the two countries researched and the United States.
2. Create a scenario in which you allocate revenues and costs to each country to determine the lowest possible overall tax for each country. Provide
support for your allocations.
3. Propose a scenario to the client that will result in a favorable tax position. Provide support for your position.
4. Analyze how the Internal Revenue Service (IRS) uses Internal Revenue Code (IRC) section 482 to prevent shifting of profits to other countries to
reduce U.S. tax liability.
5. Assume that the IRS has challenged the allocations and is preparing to audit the client. Prepare a brief position to defend the client to the IRS.
Provide support for your position.
6. Evaluate two tools IRS agents have available to perform the audit on multinational transfer pricing issues.
7. Use at least five quality resources in this assignment. Note: Wikipedia and similar websites do not qualify as quality resources.
This course requires the use of Strayer Writing Standards. For assistance and information, please refer to the Strayer Writing Standards link in the left-
hand menu of your course.
The specific course learning outcome associated with this assignment is:
Create a proposal for allocating revenues and costs that satisfies IRS codes while determining the lowest possible taxes for a multinational
company that engages in cross border transactions in two foreign countries.
Scoring Guide
Provide the name of the selected company selected and what type of
international business they are engaged in. Based on research, create
projections of revenues, costs, and tax rates based on the two countries
researched and the United States. 15 %
Unacceptable
Did not submit or incompletely
provided the name of the selected
company, and what type of
international business they are
engaged in. Did not submit or
incompletely created projections of
revenues, costs, and tax rates
based on the two countries
researched and the United States.
Needs Improvement
Partially provided the name of the
selected company, and what type
of international business they are
engaged in. Partially created
projections of revenues, costs, and
tax rates based on the two
countries researched and the
United States.
Competent
Satisfactorily provided the name of
the selected company, and what
type of international business they
are engaged in. Satisfactorily
created projections of revenues,
costs, and tax rates based on the
two countries researched and the
United States.
Exemplary
Thoroughly provided the name of
the selected company, and what
type of international business they
are engaged in. Thoroughly
created projections of revenues,
costs, and tax rates based on the
two countries researched and the
United States.
Create a scenario to allocate revenues and costs to each country to
determine the lowest possible overall tax for each country. Provide support
for the allocations. 15 %
Unacceptable
Did not submit or incompletely
created a scenario to allocate
revenues and costs to each
country to determine the lowest
possible overall tax for each
country. Did not submit or
incompletely provided support for
the allocations.
Needs Improvement
Partially created a scenario to
allocate revenues and costs to
each country to determine the
lowest possible overall tax for each
country. Partially provided support
for the allocations.
Competent
Satisfactorily created a scenario to
allocate revenues and costs to
each country to determine the
lowest possible overall tax for each
country. Satisfactorily provided
support for the allocations.
Exemplary
Thoroughly created a scenario to
allocate revenues and costs to
each country to determine the
lowest possible overall tax for each
country. Thoroughly provided
support for the allocations.
Propose a scenario to the client that will result in a favorable tax position.
Provide support for the position. 10 %
Unacceptable
Did not submit or incompletely
proposed a scenario to the client
that will result in a favorable tax
position. Did not submit or
incompletely provided support for
the position.
Needs Improvement
Partially proposed a scenario to
the client that will result in a
favorable tax position. Partially
provided support for the position.
Competent
Satisfactorily proposed a scenario
to the client that will result in a
favorable tax position.
Satisfactorily provided support for
the position.
Exemplary
Thoroughly proposed a scenario to
the client that will result in a
favorable tax position. Thoroughly
provided support for the position.
Analyze how the Internal Revenue Service (IRS) uses Internal Revenue Code
(IRC) section 482 to prevent shifting of profits to other countries to reduce
U.S. tax liability. 15 %
Unacceptable
Did not submit or incompletely
analyzed how the Internal
Revenue Service (IRS) uses
Internal Revenue Code (IRC)
section 482 to prevent shifting of
profits to other countries to reduce
U.S. tax liability.
Needs Improvement
Partially analyzed how the Internal
Revenue Service (IRS) uses
Internal Revenue Code (IRC)
section 482 to prevent shifting of
profits to other countries to reduce
U.S. tax liability.
Competent
Satisfactorily analyzed how the
Internal Revenue Service (IRS)
uses Internal Revenue Code (IRC)
section 482 to prevent shifting of
profits to other countries to reduce
U.S. tax liability.
Exemplary
Thoroughly analyzed how the
Internal Revenue Service (IRS)
uses Internal Revenue Code (IRC)
section 482 to prevent shifting of
profits to other countries to reduce
U.S. tax liability.
Assume that the IRS has challenged the allocations and is preparing to audit
the client. Prepare a brief position to defend the client to the IRS. Provide
support for the position. 15 %
Unacceptable
Did not submit or incompletely
prepared a brief position to defend
the client to IRS, assuming that the
IRS has challenged the allocations
and is preparing to audit the client.
Did not submit or incompletely
provided support for the position.
Needs Improvement
Partially prepared a brief position
to defend the client to IRS,
assuming that the IRS has
challenged the allocations and is
preparing to audit the client.
Partially provided support for the
position.
Competent
Satisfactorily prepared a brief
position to defend the client to IRS,
assuming that the IRS has
challenged the allocations and is
preparing to audit the client.
Satisfactorily provided support for
the position.
Exemplary
Thoroughly prepared a brief
position to defend the client to IRS,
assuming that the IRS has
challenged the allocations and is
preparing to audit the client.
Thoroughly provided support for
the position.
Evaluate two tools IRS agents have available to perform the audit on
multinational transfer pricing issues. 15 %
Unacceptable
Did not submit or incompletely
evaluated two tools IRS agents
have available to perform the audit
on multinational transfer pricing
issues.
Needs Improvement
Partially evaluated two tools IRS
agents have available to perform
the audit on multinational transfer
pricing issues.
Competent
Satisfactorily evaluated two tools
IRS agents have available to
perform the audit on multinational
transfer pricing issues.
Exemplary
Thoroughly evaluated two tools
IRS agents have available to
perform the audit on multinational
transfer pricing issues.
Five references. 5 %
Unacceptable
No references provided.
Needs Improvement
Does not meet the required
number of references; some or all
references poor quality choices.
Competent
Meets number of required
references; all references high
quality choices.
Exemplary
Exceeds number of required
references; all references high
quality choices.
Clarity, writing mechanics, and formatting requirements. 10 %
Unacceptable
More than 6 errors present.
Needs Improvement
5–6 errors present.
Competent
3–4 errors present.
Exemplary
0–2 errors present.
w08a1 - International Taxation and Foreign Tax Credits
Summary
Click the linked activity title to access the assignment.
Text
Overview
For this assignment, assume that 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. To complete this assignment, please select a U.S.-based corporation that has expanded into foreign markets within the
last seven years.
Instructions
Using the Internet and/or Strayer Library, conduct research on the tax impacts for U.S. companies expanding into foreign markets.
Write a 4–6-page paper in which you:
1. Analyze, based on your research, the major impact of the Tax Cuts and Jobs Act on the use of controlled foreign corporations to expand abroad.
Examine two methods you would recommend to the client to circumvent the provisions of the Tax Cuts and Jobs Act on subpart F to reduce the
client’s tax liability. Provide at least two examples to support your recommendations.
2. Create a plan, based on your research, for the client to lower taxes by reinvesting profits and thereby lower the company’s tax liability. Provide at
least one example to support your plan.
3. Develop a strategy for the client to neutralize the impact of the Tax Cuts and Jobs Act on the immediate U.S. taxation of deferred income from foreign
subsidiaries' earnings and profits (E&P) over an eight-year period. Provide examples to support your plan.
4. Analyze the foreign tax credits available to your client. Propose at least three tax credits the client could use and the impact of the credits on other
foreign loss income. Provide examples to support your recommendations.
5. Use at least four quality resources in this assignment. Note: Wikipedia and similar websites do not qualify as quality resources.
This course requires the use of Strayer Writing Standards. For assistance and information, please refer to the Strayer Writing Standards link in the left-
hand menu of your course.
The specific course learning outcome associated with this assignment is:
Develop a plan to reduce tax liability, lower taxes, neutralize the impact of the Tax Cuts and Jobs Act, and use tax credits for a U.S.-based
company that has expanded into foreign markets.
Scoring Guide
Analyze, based on research, the major impact of the Tax Cuts and Jobs Act
on the use of controlled foreign corporations to expand abroad. Examine
two methods to recommend to the client to circumvent the provisions of the
Tax Cuts and Jobs Act on subpart F to reduce the client’s tax liability.
Provide at least two examples to support recommendations. 20 %
Unacceptable
Did not submit or incompletely
analyzed the major impact of the
Tax Cuts and Jobs Act on the use
of controlled foreign corporations
to expand abroad. Did not submit
or incompletely examined two
methods to recommend to the
client to circumvent the provisions
of the Tax Cuts and Jobs Act on
subpart F to reduce the client’s tax
liability. Did not submit or
incompletely provided at least two
Needs Improvement
Partially analyzed the major impact
of the Tax Cuts and Jobs Act on
the use of controlled foreign
corporations to expand abroad.
Partially examined two methods to
recommend to the client to
circumvent the provisions of the
Tax Cuts and Jobs Act on subpart
F to reduce the client’s tax liability.
Partially provided at least two
examples to support
recommendations.
Competent
Satisfactorily analyzed the major
impact of the Tax Cuts and Jobs
Act on the use of controlled foreign
corporations to expand abroad.
Satisfactorily examined two
methods to recommend to the
client to circumvent the provisions
of the Tax Cuts and Jobs Act on
subpart F to reduce the client’s tax
liability. Satisfactorily provided at
least two examples to support
recommendations.
Exemplary
Thoroughly analyzed the major
impact of the Tax Cuts and Jobs
Act on the use of controlled foreign
corporations to expand abroad.
Thoroughly examined two
methods to recommend to the
client to circumvent the provisions
of the Tax Cuts and Jobs Act on
subpart F to reduce the client’s tax
liability. Thoroughly provided at
least two examples to support
recommendations.
examples to support
recommendations.
Create, based on research, a plan for the client to lower taxes by reinvesting
profits and thereby lower the company’s tax liability. Provide at least one
example to support the plan. 20 %
Unacceptable
Did not submit or incompletely
created a plan for the client to
lower taxes by reinvesting profits
and thereby lower the company’s
tax liability. Did not submit or
incompletely provided at least one
example to support the plan.
Needs Improvement
Partially created a plan for the
client to lower taxes by reinvesting
profits and thereby lower the
company’s tax liability. Partially
provided at least one example to
support the plan.
Competent
Satisfactorily created a plan for the
client to lower taxes by reinvesting
profits and thereby lower the
company’s tax liability.
Satisfactorily provided at least one
example to support the plan.
Exemplary
Thoroughly created a plan for the
client to lower taxes by reinvesting
profits and thereby lower the
company’s tax liability. Thoroughly
provided at least one example to
support the plan.
Develop a strategy for the client to neutralize the impact of the Tax Cuts and
Jobs Act on the immediate U.S. taxation of deferred income from foreign
subsidiaries' earnings and profits (E&P) over an eight-year period. Provide
examples to support the plan. 25 %
Unacceptable
Did not submit or incompletely
developed a strategy for the client
to neutralize the impact of the Tax
Cuts and Jobs Act on the
immediate U.S. taxation of
deferred income from foreign
subsidiaries' earnings and profits
(E&P) over an eight-year period.
Did not submit or incompletely
provided examples to support the
plan.
Needs Improvement
Partially developed a strategy for
the client to neutralize the impact
of the Tax Cuts and Jobs Act on
the immediate U.S. taxation of
deferred income from foreign
subsidiaries' earnings and profits
(E&P) over an eight-year period.
Partially provided examples to
support the plan.
Competent
Satisfactorily developed a strategy
for the client to neutralize the
impact of the Tax Cuts and Jobs
Act on the immediate U.S. taxation
of deferred income from foreign
subsidiaries' earnings and profits
(E&P) over an eight-year period.
Satisfactorily provided examples to
support the plan.
Exemplary
Thoroughly developed a strategy
for the client to neutralize the
impact of the Tax Cuts and Jobs
Act on the immediate U.S. taxation
of deferred income from foreign
subsidiaries' earnings and profits
(E&P) over an eight-year period.
Thoroughly provided examples to
support the plan.
Analyze the foreign tax credits available to the client. Propose at least three
tax credits the client could use and the impact of the credits on other foreign
loss income. Provide examples to support recommendations. 20 %
Unacceptable
Did not submit or incompletely
analyzed the available foreign tax
credits to the client. Did not submit
or incompletely proposed at least
three tax credits the client could
use and the impact of the credits
on other foreign loss income. Did
not submit or incompletely
provided examples to support
recommendations.
Needs Improvement
Partially analyzed the available
foreign tax credits to the client.
Partially proposed at least three
tax credits the client could use and
the impact of the credits on other
foreign loss income. Partially
provided examples to support
recommendations.
Competent
Satisfactorily analyzed the
available foreign tax credits to the
client. Satisfactorily proposed at
least three tax credits the client
could use and the impact of the
credits on other foreign loss
income. Satisfactorily provided
examples to support
recommendations.
Exemplary
Thoroughly analyzed the available
foreign tax credits to the client.
Thoroughly proposed at least three
tax credits the client could use and
the impact of the credits on other
foreign loss income. Thoroughly
provided examples to support
recommendations.
Four references 5 %
Unacceptable
No references provided.
Needs Improvement
Does not meet the required
number of references; some or all
references poor quality choices.
Competent
Meets number of required
references; all references high
quality choices.
Exemplary
Exceeds number of required
references; all references high
quality choices.
Clarity, writing mechanics, and formatting requirements. 10 %
Unacceptable
More than 6 errors present.
Needs Improvement
5–6 errors present.
Competent
3–4 errors present.
Exemplary
0–2 errors present.
w02a1 - Foreign Source Income Rules (Client Letter)
Summary
Click the linked activity title to access the assignment.
Text
Overview
For the Foreign Source Income Rules (Client Letter), choose a company that is of interest to you that operates both in the United States and
internationally. Imagine that you are a CPA working to provide tax advice to this company. The company has specifically requested information on
strategies that they can use to minimize the tax effects of foreign sourced income.
Instructions
Use your text, the Internet, and/or Strayer Library to research the various rules regarding source rules for income and deductions.
Write a 1–2-page paper in which you:
1. Provide, on a separate page between the cover page and the Client Letter, some basic information on the company you selected, along with a brief
rationale for why you selected this company. Note: This summary does not count toward the required page length.
2. Outline, in your letter to your selected company, the source rules for income and deductions and the conditions under which income received in
foreign countries may or may not be taxed in the United States.
3. Present a proposal to the client as to how to reduce the U.S. tax impact from income received from outside the United States. Provide details to
support your proposal.
4. Use at least two quality resources in this assignment. Note: Wikipedia and similar websites do not qualify as quality resources.
This course requires the use of Strayer Writing Standards. For assistance and information, please refer to the Strayer Writing Standards link in the left-
hand menu of your course.
The specific course learning outcome associated with this assignment is:
Create a proposal for implementing strategies that reduce the U.S. tax impact of foreign sourced income.
Scoring Guide
Provide, on a separate page between the cover page and the Client Letter,
some basic information on the selected company, along with a brief
rationale for selecting this company. 10 %
Unacceptable
Did not submit or incompletely
provided some basic information
on the selected company and did
not submit or incompletely
provided a rationale for selecting
this company.
Needs Improvement
Partially provided some basic
information on the selected
company and partially provided a
rationale for selecting this
company.
Competent
Satisfactorily provided some basic
information on the selected
company and satisfactorily
provided a rationale for selecting
this company.
Exemplary
Thoroughly provided some basic
information on the selected
company and thoroughly provided
a rationale for selecting this
company.
Outline the source rules for income and deductions and the conditions
under which income received in foreign countries may or may not be taxed
in the United States. 30 %
Unacceptable
Did not submit or incompletely
outlined the source rules for
income and deductions and the
conditions under which income
received in foreign countries may
or may not be taxed in the United
States.
Needs Improvement
Partially outlined the source rules
for income and deductions and the
conditions under which income
received in foreign countries may
or may not be taxed in the United
States.
Competent
Satisfactorily outlined the source
rules for income and deductions
and the conditions under which
income received in foreign
countries may or may not be taxed
in the United States.
Exemplary
Thoroughly outlined the source
rules for income and deductions
and the conditions under which
income received in foreign
countries may or may not be taxed
in the United States.
Present a proposal to the client as to how to reduce the U.S. tax impact from
income received from outside the United States. Provide details to support
the proposal. 45 %
Unacceptable Needs Improvement Competent Exemplary
Did not submit or incompletely
presented a proposal to the client
as to how to reduce the U.S. tax
impact from income received from
outside the United States. Did not
submit or incompletely provided
details to support the proposal.
Partially presented a proposal to
the client as to how to reduce the
U.S. tax impact from income
received from outside the United
States. Partially provided details to
support the proposal.
Satisfactorily presented a proposal
to the client as to how to reduce
the U.S. tax impact from income
received from outside the United
States. Satisfactorily provided
details to support the proposal.
Thoroughly presented a proposal
to the client as to how to reduce
the U.S. tax impact from income
received from outside the United
States. Thoroughly provided
details to support the proposal.
Two references. 5 %
Unacceptable
No references provided.
Needs Improvement
Does not meet the required
number of references; some or all
references poor quality choices.
Competent
Meets number of required
references; all references high
quality choices.
Exemplary
Exceeds number of required
references; all references high
quality choices.
Clarity, writing mechanics, and formatting requirements. 10 %
Unacceptable
More than 6 errors present.
Needs Improvement
5–6 errors present.
Competent
3–4 errors present.
Exemplary
0–2 errors present.
w04a1 - Foreign Taxpayers Engaged in a Trade or Business in the United States
Summary
Click the linked activity title to access the assignment.
Text
Overview
Imagine you are an international tax consultant with a foreign client seeking to invest capital in the United States to take advantage of the growing
economy. The foreign client is trying to evaluate alternative forms of business to maximize available tax benefits. Keep in mind that the client is
requesting advice on the best methods to avoid or reduce taxes on income from the investment in a new business with other U.S. investors.
Instructions
Use the Internet and/or Strayer Library to research the rules related to foreign taxpayers engaged in a trade or business in the United States and the
related tax effects.
Write a 3–4-page paper in which you:
1. Identify, based on your research, at least two methods of conducting business in the United States for your client, and compare the tax advantages
and disadvantages of each that would have the greatest impact on the business. Provide examples to support the identified advantages and
disadvantages.
2. Examine at least three categories of U.S. sourced income that will generate U.S. taxes for your client. Provide support for your results.
3. Provide two examples from within the last three years of how foreign capital investors were able to avoid or reduce taxes on income from their
investments. Analyze the impact of the Tax Cuts and Jobs Act on each of your examples.
4. Use at least three quality resources in this assignment. Note: Wikipedia and similar websites do not qualify as quality resources.
This course requires the use of Strayer Writing Standards. For assistance and information, please refer to the Strayer Writing Standards link in the left-
hand menu of your course.
The specific course learning outcome associated with this assignment is:
Analyze the tax advantages and disadvantages of conducting business in the U.S. for a foreign capital investor seeking to maximize available tax
benefits.
Scoring Guide
Identify, based on research, at least two methods of conducting business in
the United States for the client, and compare the tax advantages and
disadvantages of each that would have the greatest impact on the business.
Provide examples to support the advantages and disadvantages identified.
30 %
Unacceptable Needs Improvement Competent Exemplary
© 2020 Strategic Education, Inc.
Did not submit or incompletely,
identified at least two methods of
conducting business in the United
States for the client, and did not
submit or incompletely compared
the tax advantages and
disadvantages of each that would
have the greatest impact on the
business. Did not submit or
incompletely provided examples to
support the identified advantages
and disadvantages.
Partially identified at least two
methods of conducting business in
the United States for the client, and
partially compared the tax
advantages and disadvantages of
each that would have the greatest
impact on the business. Partially
provided examples to support the
identified advantages and
disadvantages.
Satisfactorily identified at least two
methods of conducting business in
the United States for the client, and
satisfactorily compared the tax
advantages and disadvantages of
each that would have the greatest
impact on the business.
Satisfactorily provided examples to
support the identified advantages
and disadvantages.
Thoroughly identified at least two
methods of conducting business in
the United States for the client, and
thoroughly compared the tax
advantages and disadvantages of
each that would have the greatest
impact on the business.
Thoroughly provided examples to
support the identified advantages
and disadvantages.
Examine at least three categories of U.S. sourced income that will generate
U.S. taxes for the client. Provide support for results. 30 %
Unacceptable
Did not submit or incompletely
examined at least three categories
of U.S. sourced income that will
generate U.S. taxes for the client.
Did not submit or incompletely
provided support for results.
Needs Improvement
Partially examined at least three
categories of U.S. sourced income
that will generate U.S. taxes for the
client. Partially provided support
for results.
Competent
Satisfactorily examined at least
three categories of U.S. sourced
income that will generate U.S.
taxes for the client. Satisfactorily
provided support for results.
Exemplary
Thoroughly examined at least
three categories of U.S. sourced
income that will generate U.S.
taxes for the client. Thoroughly
provided support for results.
Provide two examples from within the last three years of how foreign capital
investors were able to avoid or reduce taxes on income from their
investments. Analyze the impact of the Tax Cuts and Jobs Act on each of the
examples. 25 %
Unacceptable
Did not submit or incompletely
provided two examples from within
the last three years of how foreign
capital investors were able to avoid
or reduce taxes on income from
their investments. Did not submit
or incompletely analyzed the
impact of the Tax Cuts and Jobs
Act on each of the examples.
Needs Improvement
Partially provided two examples
from within the last three years of
how foreign capital investors were
able to avoid or reduce taxes on
income from their investments.
Partially analyzed the impact of the
Tax Cuts and Jobs Act on each of
the examples.
Competent
Satisfactorily provided two
examples from within the last three
years of how foreign capital
investors were able to avoid or
reduce taxes on income from their
investments. Satisfactorily
analyzed the impact of the Tax
Cuts and Jobs Act on each of the
examples.
Exemplary
Thoroughly provided two examples
from within the last three years of
how foreign capital investors were
able to avoid or reduce taxes on
income from their investments.
Thoroughly analyzed the impact of
the Tax Cuts and Jobs Act on each
of the examples.
Three references. 5 %
Unacceptable
No references provided.
Needs Improvement
Does not meet the required
number of references; some or all
references poor quality choices.
Competent
Meets number of required
references; all references high
quality choices.
Exemplary
Exceeds number of required
references; all references high
quality choices.
Clarity, writing mechanics, and formatting requirements. 10 %
Unacceptable
More than 6 errors present.
Needs Improvement
5–6 errors present.
Competent
3–4 errors present.
Exemplary
0–2 errors present.
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