International Taxation and Foreign Tax Credits

Assignment 3: International Taxation and Foreign Tax
Credits

Due Week 6 and worth 280 points (Due in 4 Weeks)

Assume you are a CPA working as a tax professional and are
hired by a client who is a U.S.-based taxpayer and is interested in expanding
the business into foreign markets. 

Using the Internet or Strayer databases, conduct research
on the various tax impacts for U.S. companies that expand abroad.

Write a four to six (4-6) page paper in which you:

1. Based on your research, assess at least two (2) types
   of organizations that the taxpayer could establish abroad and the various
   tax impacts that these types of organization may cause. Provide support for your rationale.
2. Based on your research, develop a strategy for the
   client to repatriate earnings from the foreign markets and avoid or
   mitigate the U.S. tax impact on repatriation. Provide support for your
   rationale.
3. Based on your research, evaluate foreign tax credits
   and propose at least three (3) tax credits the client could use and the
   impact on the taxes. Provide examples with your rationale.
4. Based on your research, assess the impact that the
   accumulated earnings tax had on the client and how the tax could be
   avoided or mitigated. Provide examples with your rationale.
5. Based on your research, analyze the rules regarding
   potential U.S. and foreign sourced losses and propose scenario to your
   client that would best represent the proper treatment of those losses. Provide
   support for your rationale.
6. Use at least four (4) quality resources in this
   assignment. Note: Wikipedia and
   similar Websites do not qualify as quality resources.

Your assignment must follow these formatting requirements:

• Be typed, double spaced, using Times New Roman font
  (size 12), with one-inch margins on all sides; citations and references
  must follow APA or school-specific format. Check with your professor for
  any additional instructions.
• Include a cover page containing the title of the
  assignment, the student’s name, the professor’s name, the course title,
  and the date. The cover page and the reference page are not included in
  the required assignment page length.

The specific course learning outcomes associated with this
assignment are:

• Analyze the legal basis of outbound
  international taxation and foreign tax credit limitations.
• Use technology and information resources to research
  issues in international tax planning and research.
• Write clearly and concisely about international tax
  planning and research using proper writing mechanics.