Content Provider
Rimon logo
Handout Materials
Presentation Slides
Additional Materials
Webinar Technical FAQs
Free cpece webinars
International Tax: Basics of Income Sourcing

INTERNATIONAL TAX: BASICS OF INCOME SOURCING

Cost Free
Presentation Length 1.5 hours

Recorded DateSeptember 18, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelIntermediate
Course Description

This course provides an overview of income sourcing rules maintained by the United States. Sourcing rules are critical for non-residents, who are almost exclusively taxed by the United States on income directly sourced to the country. Sourcing has become increasingly important for American taxpayers—particularly corporate ones, who qualify for significant deductions on foreign-sourced income. This program provides background on how sourcing determinations are made, including allocating income items between different income categories. The program will also cover special rules in the sourcing context—specifically, those related to multi-year compensation arrangements.

Learning Objectives:


  • Recall how Foreign-Derived Intangible Income (FDII) applies to corporations

  • Recall the scope of United States tax rules for non-residents

  • Identify income sourcing rules across various situations

Not logged
PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
Linkedin
Rimon logo

Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.


Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.


Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.


Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.


User-added image

 

About Our Presenter

Rimon logo
Rimon is a highly selective entrepreneurial firm that combines the dynamic client service, teamwork, and agility of a high-end boutique law firm with the deep multidisciplinary experience of a large global firm. Our clients consistently receive exceptional representation across twelve countries and five continents, from our all-star team of corporate, litigation, tax, intellectual property, entertainment, and private client attorneys.

Rimon's consistent excellence, commitment to the community, and innovation have been internationally recognized, including by Harvard Law School, Stanford Law School, Chambers, Best Lawyers, Super Lawyers, the Financial Times Innovation awards, the Atlantic, the American Bar Association's Legal Rebels, the Economist, the Recorder, and many more.

Rimon’s clients range from cutting-edge technology startups to financial institutions and Fortune 100 companies.

Rimon's attorneys come with decades of experience before even joining Rimon. Rimon's attorneys were meticulously drawn from the top ranks of premier law firms, international corporations, and academia. They hold JDs, PhDs, LLMs, and MBAs from the best universities in the United States and abroad. They have worked on multi-billion dollar deals, have won bet-the-company litigation, and have run universities. Their experience and education ensure our clients receive consistently excellent and comprehensive counsel.