Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2028 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
U.S. persons with significant interests in foreign partnerships must generally file Form 8865, Return of U.S. Persons with Respect to Certain Foreign Partnerships annually. This form is used to report information with respect to controlled foreign partnerships, transfers to foreign partnerships and acquisitions, dispositions, and other changes in foreign partnership interests. Taught by Robert Misey, author of a Practical Guide to U.S. Taxation of International Transactions.
Publication Date: November 2025
Designed For
Tax accountants, tax attorneys, and tax professionals in industry
Topics Covered
- Review of U.S. international outbound tax rules for business
- Discussion of fundamental U.S. international tax reporting rules and obligations of U.S. persons with interests in foreign partnerships
- Purpose of Form 8865
- Structure and preparation of Form 8865
- Treatment of cross-border activities and transactions
- Potential audit issues and triggers to avoid
Learning Objectives
- Recognize how to develop a practical understanding of U.S. international tax rules with respect to foreign partnerships
- Identify the laws behind the information put on Form 8865
- Identify creditable foreign taxes
- Identify the schedules to properly file Form 8865
- Identify what is an association of two or more persons who carry on as co-owners of a business for profit
- Identify the schedule of Form 8865 that includes the income statement (i.e., trade or business income)
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
Instructor
Robert J. Misey
Rob Misey is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. and Chair of the firm's International Department. He concentrates his practice in the areas of international taxation, transfer pricing and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment.
For U.S. based multinationals, Rob helps clients maximize foreign tax credits and take advantage of export benefits to reduce the client's overall effective tax rate. For foreign owned clients, he coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. Rob's significant transfer pricing experience allows him to assist multinational businesses with preparing documentation and negotiating Advance Pricing Agreements (APAs). He assists both U.S. and foreign investors in minimizing withholding taxes by taking advantage of applicable tax treaties and offshore corporations and trusts.
Rob's previous experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in its Washington, D.C. national office, where he was a member of the APA team, and a trial attorney and international tax specialist in San Jose, California and the Southeast Region. He also managed the International Tax Services group for a region of a Big Four accounting firm.
Rob regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs in numerous states and foreign countries. He has published numerous articles and is a co-author to treatises, U.S. Taxation of International Transactions and Federal Taxation Practice and Procedure, both published by CCH. Rob also teaches international taxation at the Master of Tax program in the University of Wisconsin system.
Rob received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer. A native of Milwaukee, Mr. Misey is licensed to practice in Wisconsin, California and the District of Columbia. His professional affiliations include membership in the Tax Section of the District of Columbia Bar Association. He is also a former Chair of the International Practice Section of the Wisconsin State Bar.