You are a CPA professional and are assisting a new client who is expanding a business that operates in the United States to having a global presence with operations in foreign countries. The new client is concerned about how he can mitigate the U.S. tax impact from revenue sourced in foreign countries. The client was advised by a friend that claims he did not have to pay any U.S. tax on income received from outside the U.S. Use the Internet and your text to research the various rules regarding source rules for income and deductions. Write a one to two (1-2) page paper in which you:
1. Construct a letter to communicate to your client about the source rules for income and deductions and the circumstances that income received in foreign countries may or may not be taxed in the U.S.
2. Make a recommendation to the client as to how to mitigate the U.S. tax impact from income received from outside the U.S. Provide facts to support your recommendation.
3. Use at least two (2) quality resources in this assignment. Note: Wikipedia and similar Websites do not qualify as quality resources.
Your assignment must follow these formatting requirements:
• Be typed, double-spaced, using Times New Roman font (size 12), with one-inch margins on all sides; citations and references must follow APA or school-specific format. Check with your professor for any additional instructions.
• Include a cover page containing the title of the assignment, the student’s name, the professor’s name, the course title, and the date. The cover page and the reference page are not included in the required assignment page length. The specific course learning outcomes associated with this assignment are:
• Analyze the source rules reach of the U.S. Tax Code in regard to international taxation.
• Use technology and information resources to research issues in international tax planning and research.
• Write clearly and concisely about international tax planning and research using proper writing mechanics. Grading for this assignment will be based on answer quality, logic / organization of the paper, and language and writing skills, using the following rubric.