Check-the-Box Elections for Foreign Subsidiaries: Achieving Optimal Tax Treatment Through Entity Selection
Using Hybrid Entities for Tax Arbitrage, Structuring Entities to Enable Deferral of Foreign Profits
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with thorough and practical guidance on the advantages and pitfalls of utilizing the “check the box” election for foreign subsidiaries. The panel will discuss the various tax impacts to specific elections, outlining the tax timing and tax treatment, both deferred and on repatriation, of income from foreign subsidiaries.
- Purpose of “check-the-box” entity election
- Relevance determination for foreign entities
- Hybrid entities and tax planning opportunities
- Income transfer opportunities out of Subpart F
- Planning tax analysis for initial entity selection
- Making retroactive entity selection or reevaluation
The panel will discuss these and other important issues:
- How do check-the-box elections facilitate the creation of “hybrid” entities?
- Utilizing check-the-box elections to structure transactions to pull foreign-source income out of Subpart F treatment
- Retroactive entity selection and completing Form 8832
- How to determine whether a foreign entity is “relevant” for U.S. taxation purposes
Mr. Henson has more than 23 years of experience working in both public accounting and industry. He specializes in... | Read More
Mr. Henson has more than 23 years of experience working in both public accounting and industry. He specializes in cross-border tax planning and has extensive experience in structuring and due diligence for multinational acquisitions, seller-side strategies for multinational dispositions, cross-border partnership planning, planning for foreign-owned U.S. businesses, and post-acquisition restructuring. He has significant experience in FAS 109, U.S. international tax compliance, and transaction-related tax return disclosures. He taught the cross-border mergers and acquisition course for a “Big 4” firm, was an adjunct professor at Cooley Law School, and frequently speaks on international tax topics.Close
Alison N. Dougherty, J.D., LL.M.
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and... | Read More
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She specializes in international tax compliance, planning and structuring as a subject matter leader of her firm's international tax practice. Her responsibilities include U.S. Federal and multi-state tax compliance for C corporations, S corporations, partnerships and individuals. She also provides transactional tax planning and structuring services.Close
Pamela A. Fuller, JD, LLM
Gremminger Law Firm
Ms. Fuller has broad experience in federal, state, and international tax planning matters. She counsels foreign and... | Read More
Ms. Fuller has broad experience in federal, state, and international tax planning matters. She counsels foreign and U.S. based companies, their executives, and high-net-worth individuals, in structuring their transactions and investments for optimal tax and business results. She is experienced in complex tax issues, including transfer pricing disputes. She helps U.S. persons holding foreign accounts and assets to comply with their U.S. tax filing obligations - including those pertaining to FBAR and FATCA. She frequently publishes in the areas of international tax planning, dispute resolution, capital markets, and comparative securities law.Close