Taxation of Income Earned by Foreign Subsidiaries
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Who is AICPA?
AICPA (the Association) represents AICPA® & CIMA®.
The Association has over 696,000 members in 192 countries. AICPA is the worldwide leader on public and management accounting issues through support for the CPA license, specialized credentials, professional education & thought leadership.
Official AICPA & CIMA Taxation of Income Earned by Foreign Subsidiaries — 7 CPE credits of intermediate online self-study. Covers CFC status, U.S. shareholder rules, Subpart F income, earnings and profits, Section 962 elections, PFICs and foreign asset reporting in a U.S. international tax context. Part of the U.S. International Tax Certificate pathway. Eduyush is an official AICPA & CIMA channel partner serving learners worldwide, with prices displayed in your regional currency at checkout.
7 CPE credits · NASBA: Taxes · Intermediate level · Online self-study · 1-year access · SKU ITCC25SSO
Key takeaways
- Official course title: Taxation of Income Earned by Foreign Subsidiaries (product number ITCC25SSO)
- CPE value: 7 CPE credits in the NASBA field of study: Taxes
- Level: Intermediate — best after basic international tax and inbound/outbound concepts
- Main topics: CFCs, U.S. shareholders, Subpart F income, earnings & profits, Section 962 elections, PFICs and foreign asset reporting
- Badge route: Standalone course earns CPE only — the digital badge requires the U.S. International Tax: Inbound and Outbound Transactions bundle
- Authored by: Eric Gabbai, Kyle Brandon, Christopher Summer, Farid Khosravi and David Zaiken
What is Taxation of Income Earned by Foreign Subsidiaries?
This AICPA & CIMA CPE self-study course focuses on U.S. income taxation rules for foreign subsidiaries. AICPA & CIMA categorise it as CPE self-study. It explains how CFC status, U.S. shareholder definitions, Subpart F income, E&P, PFICs and foreign asset reporting affect cross-border tax analysis.
This course is more technical than a foundation course because it moves from identifying inbound and outbound transactions to analysing income earned through foreign subsidiaries. It is especially useful for professionals supporting multinational groups, U.S. shareholders or clients with foreign investment structures.
Official course facts
| Course item | Verified detail |
|---|---|
| Official title | Taxation of Income Earned by Foreign Subsidiaries |
| Provider | AICPA & CIMA |
| Format | CPE Self-study, Online |
| CPE credits | 7 CPE |
| NASBA field of study | Taxes |
| Level | Intermediate |
| Authors | Eric Gabbai, Kyle Brandon, Christopher Summer, Farid Khosravi and David Zaiken |
| Digital badge | Not on the standalone course — earned via the U.S. International Tax: Inbound and Outbound Transactions bundle |
| Availability | 1 year after purchase date with full paid access |
| Product number | ITCC25SSO |
| Official source | AICPA & CIMA course page |
Who provides what
| Role | Organisation |
|---|---|
| Course provider | AICPA & CIMA (Association of International Certified Professional Accountants) |
| Course authors | Eric Gabbai, Kyle Brandon, Christopher Summer, Farid Khosravi and David Zaiken |
| Authorised reseller and purchase support | Eduyush |
Who should take this course?
| Learner profile | Fit | Why it helps |
|---|---|---|
| Corporate tax professional | Strong fit | Understand CFC status, Subpart F income and E&P concepts for foreign subsidiaries. |
| Public accounting tax staff | Strong fit | Support clients with foreign subsidiary structures and sharpen issue-spotting. |
| Finance manager in a multinational | Good fit | Discuss CFC, PFIC and foreign asset reporting issues with advisers more confidently. |
| CA, CPA, ACCA or CMA learner | Good fit | Targeted CPE on foreign subsidiaries and anti-deferral concepts. |
| Learner new to the vocabulary | Foundation first | Complete the foundation and inbound/outbound courses before this intermediate module. |
What you learn
You learn how to identify controlled foreign corporations and U.S. shareholders, differentiate Subpart F income types, apply E&P concepts, understand Section 962 election mechanics, and recognise PFIC and foreign asset reporting consequences.
Official key topics: U.S. outbound transactions, Subpart F income, earnings and profits in an international context, and Passive Foreign Investment Companies and foreign assets.
Official learning outcomes:
- Identify a controlled foreign corporation (CFC) and a U.S. shareholder.
- Identify the mechanics of Section 962 elections.
- Differentiate among Subpart F income types.
- Identify situations that create Subpart F income for a U.S. entity.
- Identify common E&P adjustments.
- Apply E&P concepts to common international tax transactions.
- Determine the consequences of PFIC ownership.
- Identify PFIC reporting requirements and foreign asset reporting requirements beyond PFICs.
How this course fits the certificate pathway
The comparison below is Eduyush guidance to help you sequence your learning.
| Option | Best for | Credential note |
|---|---|---|
| International Tax Foundation | The first basic introduction to U.S. international tax vocabulary. | Standalone; Core Concepts bundle needed for the badge. |
| Introduction to U.S. Outbound and Inbound Transactions | Transaction-level inbound and outbound coverage before foreign subsidiary rules. | Standalone; Core Concepts bundle needed for the badge. |
| Taxation of Income Earned by Foreign Subsidiaries (this course) | Targeted CFC, Subpart F, E&P, PFIC and foreign asset reporting coverage. | Standalone; Inbound and Outbound Transactions bundle needed for the badge. |
| U.S. International Tax Certificate | The complete pathway across core, inbound/outbound and advanced topics. | 51.5 CPE, intermediate, 2-year availability. |
Practical examples
| Situation | The first questions |
|---|---|
| A U.S. parent owns a foreign subsidiary | Whether the entity is a CFC and which persons are U.S. shareholders. |
| A foreign subsidiary earns passive income | Which Subpart F category applies and whether current U.S. inclusion arises. |
| A finance team reviews E&P adjustments | Why E&P is not always the same as book profit in common transactions. |
| An individual investor holds a foreign fund | PFIC consequences and reporting requirements beyond normal investment income. |
Why buy this course through Eduyush?
Eduyush is an authorised reseller of selected AICPA & CIMA learning products, serving learners worldwide. Prices are displayed in your regional currency at checkout, and the Eduyush team processes your enrolment so the activation email comes directly from AICPA within 1–2 working days.
Eduyush support includes
- Regional pricing support where available for eligible learners, with checkout in your local currency
- Enrolment processed by the Eduyush team — AICPA activation email within 1–2 working days
- Guidance on whether this course, a bundle or the full certificate fits your goal
- Activation and access guidance after purchase
- Support for teams and firms buying multiple AICPA & CIMA learning products
Comparing options? Review Introduction to U.S. Outbound and Inbound Transactions, the advanced module U.S. Transfer Pricing and Global BEPS, or the full U.S. International Tax Certificate.
FAQs on Taxation of Income Earned by Foreign Subsidiaries
What is the official product number?
The official AICPA & CIMA product number is ITCC25SSO.
How many CPE credits does it provide?
The official listing shows 7 CPE credits in the Taxes field of study. Learners should check their own professional body rules before claiming credit.
Is this course basic or intermediate?
AICPA lists the level as Intermediate. It is better suited to learners who already understand basic international tax and inbound/outbound concepts.
Does the standalone course include a digital badge?
No. The standalone course earns CPE only. AICPA states the U.S. International Tax: Inbound and Outbound Transactions bundle must be purchased to earn the digital badge.
What topics are covered?
U.S. outbound transactions, Subpart F income, earnings and profits in an international context, PFICs and foreign assets.
Should I take Introduction to U.S. Outbound and Inbound Transactions first?
If you are still building your international tax foundation, yes. That course gives a useful transaction-level base before moving into foreign subsidiary taxation.
How soon do I get access after buying through Eduyush?
After you enrol through Eduyush, the Eduyush team processes your enrolment and the activation email comes directly from AICPA within 1 to 2 working days. This is a digital product, so no physical materials are shipped, and access lasts 1 year from purchase.
Last verified: Official AICPA course facts checked on 13 July 2026 against the official AICPA & CIMA product page. Details may change. Learners should verify pricing, access, CPE eligibility and course availability before purchase.
