ACC 568

"Using What You’ve Learned" Please respond to the following: • From this course, examine the single most impactful or interesting thing you learned. Explain what made it so. • Predict what you believe will be the most significant changes in international taxation you will likely see in the next few years. Explain your reasoning.

10 Other / Other University of Phoenix / ACC 568 11 Dec 2015

"International Boycott and Foreign Bribery Payments" Please respond to the following: • You have been hired by an international company identified as cooperating with a foreign country that the U.S. is boycotting. Present a defense for the company to overcome the presumption that all activities in the boycotted country involving all related persons are tainted. • Identify at least one (1) deterrent of the Internal Revenue Code (IRC

10 Other / Other University of Phoenix / ACC 568 11 Dec 2015

"Tax Arbitrage and Economic Substance" Please respond to the following: • The ability to arbitrage the differences between international tax systems is a very important aspect of international tax planning. Imagine you are an international tax advisor providing tax-planning advice to a client with operations in different international tax jurisdictions. Propose one (1) arbitrage transaction to the client using hybrid entities and one (1)

25 Other / Other University of Phoenix / ACC 568 11 Dec 2015

COLLAPSE Overall Rating: • 1 • 2 • 3 • 4 • 5 Your Rating: • 1 • 2 • 3 • 4 • 5 "Foreign Tax Currency and Transfer of Property to Foreign Corporations" Please respond to the following: • Go to the IRS Website, located at http://www.irs.gov, to search and read Notice 2014–21 (IRS Virtual Currency Guidance). Based on your review of Notice 2014-21, identify two (2)

10 Other / Other University of Phoenix / ACC 568 11 Dec 2015

Students, please view the "Submit a Clickable Rubric Assignment" in the Student Center. Instructors, training on how to grade is within the Instructor Center. Assignment 3: International Taxation and Foreign Tax Credits Due Week 8 and worth 280 points Assume 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. Using the Internet or Strayer Lea

25 Other / Other University of Phoenix / ACC 568 11 Dec 2015

"The Importance of Controlled Foreign Corporations" Please respond to the following: • Imagine you are an international tax consultant advising a client on the benefits of establishing a controlled foreign corporation (CFC). Analyze two (2) categories of foreign base company income. Next, create a scenario suggesting how a U.S. domiciled multinational entity (MNE) can use a CFC to defer income using one (1) of the categories you analyzed.

10 Other / Other University of Phoenix / ACC 568 10 Dec 2015

ACC 568 week 5 discussion "Managing Foreign Tax Credits" Please respond to the following: Go to the IRS Website, located at http://www.irs.gov, and research the latest IRS “Publication 514” Foreign Tax Credit for Individuals. Based on your research, analyze at least two (2) requirements of a foreign tax levy to qualify for the foreign tax credit. Next, predict two (2) potential impacts of the foreign tax credit on dual capacity taxp

10 Other / Other University of Phoenix / ACC 568 10 Dec 2015