Course Objective: To provide an overview of the most recent developments in U.S. inbound and outbound taxation and reporting, including CFC downward attribution, sale of ECI partnership interests, Form 1042/1042-S, FATCA/CRS (Cayman), PFICs, and draft Schedule K-2/K-3 (2022 for tax year 2021).

Learning Outcomes: Participants will be able to:

  • Understand how CFC downward attribution is applied
  • Discuss when a fund needs to withhold on the sale of partnership interest
  • Be able to comply with FATCA/CRS and Form 1042 reporting