4.5 (10)

Patrick McCormick, DL, LLM

Culhane Meadows

Before starting this self study program, please go through the instructional document.


  • Challenges to the Global Businesses and context of the presentation2 mins
  • Foreign Entities – Entity Classification5 mins
  • Relevance Determination for Foreign entities12 mins
  • Foreign Entities entering in the US18 mins
  • ECI – Effectively connected Income for Foreign Entities24 mins
  • Foreign Investment in United States Real Property – FIRPTA26 mins
  • Foreign Entities – Branch Profits Tax33 mins
  • Foreign Entities – FDAP Income37 mins
  • Nonresident Alien Employees And Filing Requirements43 mins
  • Double Taxation Options48 mins
  • US entities – Taxation of foreign transactions, Taxation Under TCJA, Foreign Partners of US Partnership57 mins
  • FBAR72 mins

Course Description

Establishing and maintaining an effective tax strategy for an internationally active business or client has never been easy. Constantly expanding markets have led to global opportunities for businesses; the tax consequences of international activities are often misunderstood.  It requires tracking the constantly shifting tax landscape in multiple jurisdictions and building a cohesive structure.

This comprehensive program will go a long way in helping CPAs gain a general understanding of the complexities of international taxation. Practitioners will learn about the importance of :

  • The income-sourcing rules in international tax planning and compliance work
  • The special source rules that apply to different kinds of income
  • The fundamentals of foreign tax credit calculation
  • The U.S. taxation of foreign source income. 

In this webinar, we will introduce the most common concepts and concerns for businesses in this realm, looking at both foreign entities entering the United States and United States entities operating overseas. Coverage will include how foreign entities are classified for tax purposes, activities which make foreign entities subject to United States tax, United States rules for taxing international activities, modifications made by the Tax Cut and Jobs Act, and forms commonly used for international business activities.

This course is most beneficial to professionals new to international taxation. These individuals are often at the staff or entry level in an organization. 

Learning Objectives

  • International Tax
  • International Tax Concepts & Concerns

Who Should Attend?

  • CPA - Small Firm
  • CPA - Mid Size Firm





Patrick did an awesome job with some very complex and ever changing International sections. It is evident he is a Specialist in these areas and he attempted to pass a significant part of his knowledge on to us in a short time frame. Great Job !


Complex subject. I believe the webinar required more time to discuss the things in detail. However, Patrick is an excellent speaker & did a great job.


Presentation went very quickly but that was necessary with the time allotted. Patrick was very knowledgeable on these topics - I would use their firm for Intl Tax issues.


Mr. McCormick provides excellent detailed information along with good oversight of complicated topics. This webinar was fantastic.




Good General Information ! The webinar was very Informative with good examples and explanations.