Stephen C. Fox, CPA
U.S. International Tax
International Tax
2017 Tax Changes +
Section 965 Inclusion and Deduction
IC-DISC Export Tax Incentive
Check the Box Election
Transfer Pricing +
Shared Services
Cost Sharing
Controlled Foreign Corporations
Foreign Tax Credit Limitation
Hybrids
Commissionaires & Stripped Distributors
FIN 48
Structure Planning
International Tax Returns
Expatriate Tax +
Tax Returns for American Expats
Do I Need to File?
Tax Return Process
Foreign Earned Income Exclusion
Expat Tax Counting Days
Foreign Tax Credit for Expats
Foreign Bank Account Reporting
Expatriation
Information Needed for Your Return
Ideas
Journal Articles
Tips for CPAs
International Tax Basics +
Foreign Tax Credit
Controlled Foreign Corporations
Withholding Tax
Bio
Contact Us
Privacy and Security
Tax Education
Stephen C. Fox
, CPA, CMA
PO Box 880695
Port Saint Lucie, FL 34988
+1(973) 610-5669
Materials for my students at Fairleigh Dickinson University:
Some materials are out of date! Also visit the
Tax Education Blog
International Corporate Tax course syllabus
International Corporate Tax: Topics 1-5
International Corporate Tax: Chart for course-wide example
International Corporate Tax: Source of Income Worksheet
# International Corporate Tax: Speaking Notes through Tax Treaties
(old)
International Corporate Tax: outline part 2 thru FTC limit, up to 902 (old)
International Corporate Tax: outline part 3 thru R&D apport (old)
International Corporate Tax: outline through Interest Apport
(old)
See link at left for journal articles. The "2002" article is the first one, "International Tax Planning for Closely Held U.S. Businesses.
OECD Model Treaty & full commentary
Old OECD commentary (1992) on Article 5
FIN 48 Overview
Sample FIN 48 writeup
Sample FIN 48 calculation
International Corp. Tax: Outline--Subpart F, PFIC, Check the Box
(old)
Intl Corp Tax: Written Assignment
Outline after Subpart F
(old)
It's your business: g
et personal.
Call Steve Fox at 1(973) 610-5669 or email
steve @ sfoxcpa .com
Get the best tax
reference
source
, available for your desktop or portable
device:
Income Tax in the USA 2016