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International Tax: Basics of Income Sourcing

INTERNATIONAL TAX: BASICS OF INCOME SOURCING

Cost Free
Presentation Length 1.5 hours

Recorded DateJuly 8, 2022
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

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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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.
 

About Our Presenter

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McCormick Tax was established in 2022 to serve clients worldwide – no matter their size – on any and all needs in the United States international tax context. Our clients range from multi-billion dollar business enterprises to cost-sensitive startups, high-net-worth individuals to those with lower net worths but discrete (and often complex) international tax needs. Our firm’s founder – a non-accountant international tax attorney - has previously served as a partner (exclusively focused on international tax work) at an AmLaw200 law firm, a boutique tax, trusts and estates law firm, and a tax-focused accounting firm, giving extensive experience both with every aspect of international tax rules and every type of client with international tax needs. Transitioning from a large firm to an independent practice has also enabled our firm’s practitioners to significantly reduce their hourly billable rates – creating efficiencies for our clients and allowing us to work with clients of all sizes.

Our firm covers every aspect of United States international tax, trusts, and estates rules; we also assist our clients on more domestic-oriented United States tax needs. We work directly with clients; we also serve as “outsourced international tax counsel” for accounting, law, and advisory firms around the world. In that role, we assist wherever beneficial with those firms’ client needs in the international tax context, allowing those firms to hang onto clients/continue to work with those clients rather than losing them to firms with internal international tax teams. Our firm’s independent status gives us enormous flexibility in how we structure representations, ensuring we can serve in optimal fashion for whatever client needs arise.