Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2025 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
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
Instructor
Adnan Islam
Adnan Islam, Esq., CPA, is a partner with Friedman LLP, co-chair of the International Tax Services group, and a leader of its Blockchain/Digital Asset Transactions group. He has nearly 17 years of public accounting experience as a licensed tax attorney and CPA. Adnan has served an array of industries and clients ranging from startups to publicly traded companies including Avon, MeadWestVaco, Honeywell, Verizon, Agilent, SunGard, Booz Allen, IDT, SunGard, AMEX, OUAI, IBISWorld, Conair, Grayscale, DCG, and various blockchain and crypto (digital asset) companies, exchanges, and private equity and hedge funds. Adnan specializes in cross-border strategies, comprehensive inbound tax services, global information reporting, and structuring for crypto funds, companies, and exchanges.
As an industry thought leader, Adnan has lectured on international tax at TEI events, AICPA seminars and served as an adjunct professor for Golden Gate University Master’s in Tax curriculum. Adnan’s expertise includes advising clients at all stages of business and restructuring, with respect to FDII, GILTI, 245A DRD, subpart F, PFICs, and other issues. Additionally, Adnan empowers his clients’ decision-making and improves their supply chain and operational efficiency, including the use of holding companies, treaty country networks, and affirmative tax planning through comparative rate modeling.
Adnan is a licensed attorney admitted to practice law in New Jersey, DC, and California and a Certified Public Accountant (NY & CA). He holds a Juris Doctor (J.D.) and an M.B.A. from Rutgers University; an LL.M. in Taxation from the New York University School of Law; a blockchain business certificate from MIT; and is currently enrolled in Georgetown Law's Tax LL.M. (International Tax Certificate) program. Adnan has been admitted as a Certified Legal Specialist in Tax Law by the State Bar of California. He also is an (inactive) enrolled agent (through IRS exam).