1.
Describe and diagram the timeline that most businesses use
to enter the international markets.
2.
With respect to income generated by nonÂU.S. persons, does
the U.S. apply a âworldwideâ or a âterritorialâ
approach. Be specific.
3.
Discuss the primary purposes of income tax treaties.
4.
In international corporate income taxation, what are the
uses of the âsourcing rulesâ in computing Federal taxable
income?
5.
The § 367 crossÂborder transfer rules seem to counteract
other favorable tax provisions that allow the taxpayer to defer gross income,
e.g. §§ 351 and 368. What is the rationale for eliminating this deferral?
Provide two examples of transactions to which § 367 would apply.
6.
Your client holds foreign tax credit (FTC) carryforwards,
i.e., it is in an âexcess creditâ position. Give at least three planning ideas
that the client should implement, so as to free up the suspended FTCs.
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