International Tax & Compliance Handbook

“This publication could not have come at a better time! Rules change constantly and penalties for non-compliance are steep. I highly recommend it for both tax practitioners and individual who hold assets across borders.” 
– Sidney Kess, CPA, JD, LLM  member New York State Society of CPAs Hall of Fame.

“Cecil is a thorough professional with extensive experience and knowledge of international tax code as it applies to the United States. His deep insight on the complexities of international transactions and their tax repercussions is invaluable.”
Alka Banerjee
MD, S&P Global

“For many years, we have depended on Cecil’s expertise to navigate the myriad regulations that are part and parcel of modern day business. I have found him to be extremely insightful with an intricate knowledge of the prevailing regulatory environment. I am overjoyed to see all of Cecil’s knowledge and insight being shared with the world.”
–Avik Prabhu
CEO of India-based Showtime Group, Inc.

“Cecil has always been at the forefront, visioning the future and preparing the profession. Now he tackles international tax, at a time of significant increases in commerce and money in motion, fueled by world-wide regulatory changes and technology disruption. Cecil gives our professionals a personal experience with international tax, preparing them to grab hold of one of the most complex, yet exciting opportunities for problem solving and professional growth.”
–Gale Crosley, CPA
Crosley+Company

1.01 Overview
1.02 Often omitted international tax forms
1.03 International taxes – overview – credit system vs territorial system

2.01 US Residency
2.02 US taxes entity classification
2.03 FBAR and FATCA

3.01 Sources of Income

4.01 Effectively connected business
4.02 Permanent establishment
4.03 Deduction and expenses
4.04 Process of Allocation and apportionment

5.01 Foreign tax credits and limitations
5.02 Carry back and carry forward of FTC

6.01 Foreign Operations—Organization and Structure

6.02 Controlled Foreign corporation (CFC)
6.03 Subpart F Income
6.04 Foreign Earned Income Exclusion
6.05 Passive Foreign Investment Company (PFIC )

7.01 Sourcing of Income
7.02 U.S. Trade or Business
7.03 Effectively Connected Income (ECI)
7.04 Branch Profits Tax (BPT)

8.01 Overview of Real Estate Taxation

8.02 Purchase and Structure of Real Estate Transactions

8.03 Selling Real estate

8.04 Tax Consequences

9.01 What Is Transfer Pricing?
9.02 Different Methods of Transfer Pricing

9.03 Transfer Pricing Penalties

9.04 Base Erosion and Profit Shifting (BEPS)

10.01 Purpose of Tax Treaties

10.02 International Tax treaties

10.03 India-U.S. Tax Treaty

10.04 Fixed, Determinable, Annual, and Periodic (FDAP)

11.01 Indian Taxation–Individual
11.02 Indian Corporate Taxation
11.03 Categories of Income

11.04 Property guide for NRI (Non-Resident Indians)

11.05 Foreign Tax Credits (FTC)

12.01 Foreign Account Tax Compliance Act (FATCA)
12.02 Foreign Bank Account Reporting (FBAR)
12.03 Offshore Voluntary Disclosure Initiative (OVDI)
12.04 Form 8938 Specialized Foreign Financial Assets

12.05 Intergovernmental Agreements

13.01 Major US Tax Law Changes: Individual and Pass-Through Entities

13.02 Year-End Tax Planning

13.03 International/FBAR 

13.04 Estate, Trusts, and Gift Tax

14.01 Major Highlights on Corporations

14.02 Quasi-Territorial System

14.03 One-Time Tax on Unrepatriated Profits

14.04 Intangibles GILTI and FDII

14.05 Impact of Changes on Inbound and Outbound Transactions

Appendix

A. Selected International Tax Forms

B. Template—FBAR Information Template

C. Template—India-U.S. Tax Credit Worksheet

D. Template—FBAR OVDI Penalty Template

E. Differences Between U.S. Taxes and Indian Taxes

Available with order of complete e-book or hardcover.