U.S. International Tax Certificate Earned by Alistair Bambridge
We are pleased to announce that Alistair is one of the first tax advisers to successfully complete and be awarded the U.S International Tax Certificate by the American Institute of Certified Professional Accountants.
About the U.S. International Tax Certificate
The U.S. International Tax Certificate is a comprehensive learning program to navigate the highly complex world of international taxation.
The certificate is made up of three parts to master the core principles up to the advanced complex issues.
1 - U.S. International Tax - Core Concepts
Discussing the differences between various types of global tax systems and the characteristics of each.
Reviewing entities and the considerations for each choice.
Covering the U.S. income sourcing rules.
Identifying the principles of inbound and outbound taxation - identifying transactions that generate tax issues.
The impact the Tax Cuts and Jobs Act has on international taxation.
2 - U.S. International Tax - Inbound and Outbound Transactions
Reviewing in detail the various types of inbound and outbound transactions for international tax.
Determining U.S. shareholder and controlled foreign company (CFC) status under the new rules and tax reform.
The operating rules for subpart F income.
The Foreign Tax Credit (FTC) rules and concepts.
Issues related to dual consolidated losses, foreign currency rules and regimes under U.S. tax law.
Tax rules covering sourcing, withholding and compliance issues.
3 - U.S. International Tax - Advanced Issues
The final level for the Certificate focuses on the more complex tax issues such as transfer pricing, tax treaties and issues for corporations.
The accepted transfer pricing methods and when to use each one.
How the U.S. tax treaties determine U.S. tax residency and how that impacts eligibility under the treaty.
How hybrid entities are treated under U.S. income tax treaties.
Whether a U.S. person's transfer of property to a foreign corporation qualifies for the non-recognition treatment under section 351.
Whether a reorganization or restructuring qualifies as an inversion subject to the rules of section 7874.
About the American Institute of Certified Professional Accountants
The American Institute of CPAs (AICPA) represents the CPA profession across the United States.
AICPA is the world's largest member association for the accounting profession, with more than 431,000 members and a history dating back to 1887.
Bambridge Accountants U.S Tax Advice
We specialize in helping U.S. citizens and Green Card holders with their U.S. taxes.
For U.S. expats, we can help, plan and ensure compliance with global tax regulations and expat taxes. For those that are behind with their U.S. taxes we will help them through the Streamlined Filing Procedure to catch up with the I.R.S.
We will be able to help with international tax issues, reporting foreign bank accounts to the U.S. and the issues surrounding setting up a business outside the U.S.
We will be able to discuss any queries related to double taxation, tax compliance, capital gains, subpart F inclusions and the subpart F rules and cross border tax agreements.
If you have any questions on filing your U.S. tax return in the U.S. or as a U.S. expat - feel free to contact us here.