Inbound International Taxation and Planning for the Closely Held Business (738)

Register for this course:

This class has been cancelled. Please call the office at 720-389-5900 for more information.

Meeting Times:

Monday, November 28, 2022 8:30 AM - Monday, November 28, 2022 4:30 PM
The meeting time above is expressed in MOUNTAIN TIME, which is:
Eastern Time:
10:30 AM - 6:30 PM
Central Time:
9:30 AM - 5:30 PM
Pacific Time:
7:30 AM - 3:30 PM


This course is in the past and can no longer be purchased.


Internet Course - Live Streamed

Delivery Method:

Group Internet Based

Credit Hours:

7.0 IRS Federal Tax Law MF2AY-T-01249-22-O
1.0 IRS Ethics MF2AY-E-01250-22-O

Field of Study:

Taxes - Technical (International Taxation); and Regulatory Ethics - Technical

Course Level:



Basic understanding of U.S. taxation

General Description:

The participant will learn the fundamental tax issues for a foreign person forming a U.S. entity (inbound).

Learning Objectives:

After completing this course the participant will be able to:

  • Determine the key tax concepts regarding the other nation’s tax laws.
  • Describe how other nations’ foreign tax credit affects ownership of U.S. entities.
  • Compare how the Check-the-Box rules work for a foreign person.
  • Explain the classification rules of a foreign person.
  • Distinguish between non-business income (ECI) and business income (FDAP).
  • Understand tax treaty issues of parent-subsidiary structures.
  • Plan for foreign exports to the U.S.
  • Identify issues when investing in U.S. real estate.
  • Discuss estate planning issues when a foreign person owns a U.S. business or real estate.
  • Define the branch deductions, branch profits tax, and branch interest tax.
  • Apply the base erosion tax to large closely held structures.
  • Recognize ethical and legal issues when a client has unreported foreign income.
  • Plan structuring business entities between nations.


Mark Merric is a CPA and an attorney and holds a master of taxation degree. He is an adjunct professor at the University of Denver Graduate Tax Program and the University of Colorado Denver MS in Taxation program, and a lecturer for Fudan University’s Master of Taxation program (second ranked in China). He manages his own law firm where he concentrates on domestic and international business transactions, international taxation, and estate planning. He has spoken nationally and internationally more than 600 times, authored and co-authored more than 80 articles nationally, and is quoted in the Wall Street Journal, Forbes, and the Boston Herald.

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