**CANCELLED** Mitigation of International Double Taxation

Course Details


Tuesday, January 21, 2020

4:30am – 12:00am
(Registration: 4:00am)

Field of Study


Course Number


CPE Credit

8.0 hours CPE credit

Level of Knowledge



CalCPA Education Foundation


Assumes basic knowledge of the U.S. taxation of foreign-source income.


United States taxation rules of international income underwent a radical shift due to the 2017 Tax Cuts and Jobs Act. The United States moved from a "tax me now or tax me later" treatment of international income to a "tax me now or tax me never" system. Certain foreign derived income is now subject to a territorial system of taxation while other income remains subject to the general rule of worldwide taxation at potentially favorable tax rates. There has also been in a significant change in the United States treatment of foreign taxes imposed on the income subject to the new territorial regime and the rules for claiming a foreign tax credit or deduction.

This course will examine the situations in which double taxation arises, how the United States taxes foreign source income, the rules for claiming a foreign tax credit and the opportunities to reduce the worldwide tax burden on foreign source income. 

Materials are provided as an ebook for this course.


  • How foreign source income of a United States taxpayer is taxed by the United States focusing on the structure created by the 2017 Tax Cuts and Jobs Act, and comparing it to prior law
  • The direct, indirect and “in lieu of” foreign tax credit
  • The foreign tax credit limitation and basket rules
  • § 911 Foreign Earned Income Exclusion


  • Identify which foreign taxes are eligible for the foreign tax credit.
  • Determine who is eligible to claim a foreign tax credit.
  • Understand what constitutes Global Intangible Low Taxed Income ("GILTI"), Foreign Derived Intangible income ("FDII") and the determination of tax free foreign source income.
  • Distinguish between and properly calculate the direct, indirect and "in lieu of" credit.
  • Recognize the purpose and application of the foreign tax credit limitation and basket rules.
  • Calculate the foreign earned income exclusion.
  • Identify opportunities to reduce the United States rate of taxation on foreign income and to maximize the creditability of foreign taxes.

Designed For

CPA, attorneys and tax practitioners.


Course Pricing

Member Fee

Applicable if you are a HSCPA member in good standing.

Non-Member Fee

Applicable if you are not a HSCPA member.

Your Price $375.00

CPE Choice

Learn more about CPE Choice.
This course does not qualify for CPE Choice.

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