Assignment 3: International Taxation and Foreign Tax Credits

Due Week 8 and worth 220 points 

For Assignment 3, assume that you are a CPA employed as an international tax consultant hired to provide advice to a U.S.-based client expanding operations into foreign markets. To complete this assignment please select a U.S.-based corporation that has expanded into foreign markets within the last seven years. 

Using the Internet or Strayer Library, conduct research on the tax impacts for U.S. companies expanding into foreign markets.  

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

1. Based on your research, analyze the major impact of the Tax Cuts and Jobs Act on the use of controlled foreign corporations to expand abroad. Examine two (2) methods you would recommend to the client to circumvent the provisions of the Tax Cuts and Jobs Act on subpart F to reduce the clients tax liability. Provide at least two (2) examples to support your recommendations.
2. Based on your research, create a plan for the client to lower taxes by reinvesting profits and thereby lower the companys tax liability. Provide at least one example to support your plan.
3. Develop a strategy for the client to neutralize the impact of the Tax Cuts and Jobs Act on the immediate U.S. taxation of deferred income from foreign subsidiaries’ earnings and profits (E&P) over an eight-year period. Provide examples to support your plan.
4. Analyze the foreign tax credits available to your client. Propose at least three (3) tax credits the client could use and the impact of the credits on other foreign loss income. Provide examples to support your recommendations.
5. Use at least four (4) quality resources in this assignment. Note: Wikipedia and similar websites do not qualify as quality resources.
6. Format your assignment according to the following formatting requirements:
   1. Typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides.
   2. Include a cover page containing the title of the assignment, the students name, the professors name, the course title, and the date. The cover page is not included in the required page length.
   3. Include a reference page. Citations and references must follow APA format. The reference page is not included in the required page length.