Page 13 - International Taxation IRS Training Guides

Outbound Overview

 Outbound focuses on U.S.
persons with foreign

or investments.
activities

persons are subject to tax on all income earned
 U.S.

at home or abroad.

• Except:
Deferral of income earned by foreign subsidiary,
to anti-deferral rules (e.g., Subpart F).
subject

mitigated by foreign tax credits (FTCs).
• Double taxation is

 Other outbound areas of
concern.

• Shifting of
income and/or income producing property.

• Repatriation with minimal
U.S. tax.

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