New Partnership Reporting of Foreign Items: K-2 and K-3
Author: Adnan Islam
| CPE Credit: |
1 hour for CPAs
1 hour Federal Tax Related for EAs and OTRPs
1 hour Federal Tax Law for CTEC |
This course will offer a one-hour overview of the new forms K-2 and K-3, which are fairly new and complex Partnership Reporting of Foreign Items. This is an intermediate level international tax reporting course, and will assume that the attendee has knowledge of fundamental U.S. international income tax law and rules.
Please read IRC Sections 951, 951A, 958, and 267 prior to taking the course.
Publication Date: January 2022
Designed For
Experienced international tax staff through international tax director level interested in or already practicing international taxation.
Topics Covered
- Background on new Schedules/Forms K-2 and K-3
- Forms K-2 and K-3: Advance Information and International Tax Issues
- Summary, Thoughts, and Observations
- Territorial (HK) vs. U.S. System of Worldwide Taxation
- Good Faith Efforts to Comply with Information Reporting
- FDII
- Taxation of FDII Generated by C corporations
- Subpart F Income from CFCs, Section 951(a)(1)
- Taxation of GILTI from CFCs, Section 951A
- Section 245A Foreign DRD for C Corporations
- PFIC: Sections 1291 — 1298, and Forms 8621
- BEAT overview, Section 59A
- Technical Tax Issues for Advance Planning and Consideration
Learning Objectives
- Identify fundamental international tax issues to be reported on Forms K-2 and K-3
- Recognize PBC client information required to complete Forms K-2 and K-3
- Recognize some Form K-2 and K-3 issues that may have an effect on the client's/taxpayer's current or prospective U.S. income tax status
- Identify the type of tax system used in the U.S. after the TCJA
- Describe which schedule includes the partner's share of international income, deductions, credits, etc.
- Identify the BEAT percentage tax that can apply when a U.S. corporation makes payments to a foreign related person that would otherwise be deductible
Level
Overview
Instructional Method
Self-Study
NASBA Field of Study
Taxes (1 hour)
Program Prerequisites
None
Advance Preparation
None
