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CRYPTOCURRENCY TAX UPDATE 2022
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HOME OFFICE DEDUCTION
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Free cpece webinars
Foreign Derived Intangible Income: A Detailed Dive

FOREIGN DERIVED INTANGIBLE INCOME: A DETAILED DIVE

We've reached capacity for the webinar on 11-28-2022. To accommodate our members, we've opened up a limited number of extra spaces for a small fee. If you have already registered for this webinar, there is no need to pay this accommodation fee.
Available Date(s)
Monday, November 28, 2022: 11:00AM EST
$30.00

CPE Credits 1.5 hours
Subject Area 1.5 - Taxes (Federal Tax)
CE Credits 1.0 hour
Course Id# - HURS9-T-00918-21-O
Course Level Basic
Instructional Method Group Internet Based
Prerequisites None
Advanced Preparation None
Course Description

This program will explore in detail the FDII deduction made available as part of the 2017 Tax Cuts and Jobs Act, including how it significantly buttresses arguments for multinational business enterprises to centralize activities in the United States. The program, presented by Patrick J. McCormick, will cover requirements for the deduction (who is eligible to claim the deduction and which income is deductible) and explore in detail how it can create tax savings for multinationals with foreign-sourced income.

Learning Objectives:


  • Identify taxpayers eligible for the FDII deduction

  • Determine which transactions qualify for FDII deduction benefits

  • Outline how the FDII deduction can be used in conjunction with American tax treaties to provide global tax efficiencies

  • Identify how the FDII deduction (and domestication of multinational activities) compares with GILTI inclusions/foreign incorporation

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Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.

Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.

Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.

Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
 

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Frequently Asked Questions
  • To receive CPE credit, you must register for the webinar before it starts.
  • CPE is available to all eligible participants within 24 hours of each webinar.
  • To receive CPE for multiple attendees, at least one person must sign up for the webinar. The post-webinar email contains a link to instructions for the proctor letter. Alternatively, you may log in to your account following the webinar and click on the MY ACCOUNT button to find a link to instructions. For paid courses, payment needs to be made for each attendee before credit will be issued.
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NASBA Approved

CPAacademy.org (Sponsor Id#: 111889) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222

Irs

EA Approved

CPAacademy.org (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.

CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222

About Our Presenter

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McCormick Tax was established in 2022 to serve clients worldwide – no matter their size – on any and all needs in the United States international tax context. Our clients range from multi-billion dollar business enterprises to cost-sensitive startups, high-net-worth individuals to those with lower net worths but discrete (and often complex) international tax needs. Our firm’s founder – a non-accountant international tax attorney - has previously served as a partner (exclusively focused on international tax work) at an AmLaw200 law firm, a boutique tax, trusts and estates law firm, and a tax-focused accounting firm, giving extensive experience both with every aspect of international tax rules and every type of client with international tax needs. Transitioning from a large firm to an independent practice has also enabled our firm’s practitioners to significantly reduce their hourly billable rates – creating efficiencies for our clients and allowing us to work with clients of all sizes.

Our firm covers every aspect of United States international tax, trusts, and estates rules; we also assist our clients on more domestic-oriented United States tax needs. We work directly with clients; we also serve as “outsourced international tax counsel” for accounting, law, and advisory firms around the world. In that role, we assist wherever beneficial with those firms’ client needs in the international tax context, allowing those firms to hang onto clients/continue to work with those clients rather than losing them to firms with internal international tax teams. Our firm’s independent status gives us enormous flexibility in how we structure representations, ensuring we can serve in optimal fashion for whatever client needs arise.