Sourcing Rules for Taxation of U.S. and Foreign Persons
Date: Tuesday, October 20, 2026
Instructor: Robert J. Misey
| Begin Time: |
11:00am Pacific Time
12:00pm Mountain Time
1:00pm Central Time
2:00pm Eastern Time |
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC |
|
NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
The sourcing rules are the foundation of the U.S. international tax system, determining whether income is treated as U.S.-source or foreign-source for both U.S. and foreign persons. These rules drive key tax outcomes, including whether foreign persons are subject to U.S. tax and whether U.S. persons may claim foreign tax credits. Proper characterization of income—and the related allocation and apportionment of expenses—is essential to accurate compliance and effective tax planning.
This online course provides a comprehensive, practitioner-focused review of the U.S. income sourcing rules applicable to international transactions. Led by former IRS Chief Counsel (International) attorney Robert Misey, the program explains how sourcing rules apply to various categories of income, including passive income, compensation for services, gains from the sale of real and personal property, and inventory sales. Special focus is given to the recently updated rules governing the sale of U.S.-manufactured inventory and their planning implications.
Designed for professionals advising clients with cross-border activity, this course equips participants with the technical clarity and strategic insight needed to correctly source income, allocate expenses, maximize foreign tax credit utilization, and avoid costly sourcing errors under current law.
Who Should Attend
This course is designed for tax professionals who advise individuals and businesses engaged in international activities.
Topics Covered
- Impact of sourcing rules on the taxation of foreign persons
- Impact of sourcing rules on foreign tax credits of U.S. persons
- Sourcing of passive income, including interest, dividends, rents, and royalties
- Sourcing of income from sales of real property
- Sourcing of income from sales of personal property
- Special sourcing rules for inventory sales
- Allocation and apportionment of expenses
- Sourcing of compensation for personal services
Learning Objectives
- Explain the U.S. rules for sourcing income for both U.S. and foreign persons
- Apply the rules for allocating and apportioning expenses between U.S.-source and foreign-source income
- Determine when gain realized by a U.S. person abroad is treated as foreign-source income
- Identify payments excluded from personal services income under sourcing rules
- Analyze the sourcing rules applicable to U.S.-manufactured inventory and recent changes affecting exporters
Level
Basic
Instructional Method
Group: Internet-based
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
