T516 International Taxation II

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An introduction to the practice of US tax law with respect to the conduct by US persons of business and investment outside the US either directly or through non-US entities. This course seeks to strike a balance between the technical detail within the US tax law and the practical application of that…

Jeffery Kadet

  • Oct 13, 2011 LATEST EPISODE
  • infrequent NEW EPISODES
  • 30m AVG DURATION
  • 41 EPISODES


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Latest episodes from T516 International Taxation II

T516 Course Description and Content

Play Episode Listen Later Oct 13, 2011


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1-01 Intro to Course Including Admin Matters

Play Episode Listen Later Oct 13, 2011 17:55


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1-02 Goals - What You'll Understand - Cisco

Play Episode Listen Later Oct 13, 2011 26:39


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1-03 Case Study Format and "Big-Big Picture"

Play Episode Listen Later Oct 13, 2011 44:53


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1-04 "Big Picture" for this Course

Play Episode Listen Later Oct 13, 2011 12:18


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1-05 Methodology of Tax Practice

Play Episode Listen Later Oct 13, 2011 15:10


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1-06 Look-Back to International Tax I – Mostly "Check-the-Box"

Play Episode Listen Later Oct 13, 2011 67:26


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1-07 Look-Back to International Tax I – Source of Income and Treaties

Play Episode Listen Later Oct 13, 2011 13:26


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2-01 Overall Economics of FTC

Play Episode Listen Later Oct 13, 2011 18:55


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2-02 Who is the Taxpayer and Deduction vs Credit

Play Episode Listen Later Oct 13, 2011 67:45


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2-03 What is a Creditable Tax?

Play Episode Listen Later Oct 13, 2011 38:27


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2-04 Deemed-Paid FTC

Play Episode Listen Later Oct 13, 2011 40:17


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2-05 §904 FTC Limitation – Introduction

Play Episode Listen Later Oct 13, 2011 34:43


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2-06 §904(d) Separate FTC Limitation Baskets

Play Episode Listen Later Oct 13, 2011 53:44


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2-07 §904(f) Overall Foreign Loss, etc

Play Episode Listen Later Oct 13, 2011 26:15


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2-08 Effect of Tax Treaties on the FTC

Play Episode Listen Later Oct 13, 2011 14:47


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3-01 Subpart F and 1248 -- Introduction

Play Episode Listen Later Oct 13, 2011 65:59


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3-02 §§951 and 952 Income Inclusions, US Shareholders, etc

Play Episode Listen Later Oct 13, 2011 28:28


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3-03 §954 Foreign Base Company Income

Play Episode Listen Later Oct 13, 2011 63:42


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3-04 §956 Investment in US Property

Play Episode Listen Later Oct 13, 2011 14:06


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3-05 §§957 and 958 Definition of CFC

Play Episode Listen Later Oct 13, 2011 34:16


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3-06 §959 Previously Taxed Income

Play Episode Listen Later Oct 13, 2011 13:22


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3-07 Hopscotch Pattern

Play Episode Listen Later Oct 13, 2011 13:32


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3-08 Special Issues – FPHCI

Play Episode Listen Later Oct 13, 2011 27:10


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3-09 Special Issues – FBCSI

Play Episode Listen Later Oct 13, 2011 24:01


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3-10 §1248

Play Episode Listen Later Oct 13, 2011 13:56


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4-01 PFICs

Play Episode Listen Later Oct 13, 2011 46:59


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5-01 Transfer Pricing -- Introduction and Macro View

Play Episode Listen Later Oct 13, 2011 25:35


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5-02 Basic Concepts

Play Episode Listen Later Oct 13, 2011 63:07


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5-03 Transfer Pricing Methods

Play Episode Listen Later Oct 13, 2011 28:59


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5-04 Special Issues

Play Episode Listen Later Oct 13, 2011 32:07


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5-05 Recognizing Issues and Managing Risk

Play Episode Listen Later Oct 13, 2011 16:22


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5-06 The Future

Play Episode Listen Later Oct 13, 2011 10:27


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6-01 Bringing It All Together -- Supply Chain Case Study -- Introductory Comments

Play Episode Listen Later Oct 13, 2011 8:09


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6-02 Functions and Risks

Play Episode Listen Later Oct 13, 2011 20:10


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6-03 TP Issues Including Contract Manufacturing and Limited-Risk Distributors

Play Episode Listen Later Oct 13, 2011 32:34


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6-04 Subpart F and Disregarded Entity Issues

Play Episode Listen Later Oct 13, 2011 22:51


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6-05 Moving IP Overseas Including TP Consequences

Play Episode Listen Later Oct 13, 2011 25:51


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7-01 Non-Recognition Transactions - §367

Play Episode Listen Later Oct 13, 2011 63:52


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8-01 Tax Treaties – Outbound Aspects

Play Episode Listen Later Oct 13, 2011 15:27


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9-01 Foreign Currency Issues

Play Episode Listen Later Oct 13, 2011 10:09


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