Complex Issues With Schedule K-2 and K-3 Reporting: Tiered Partnerships, GILTI HTE, FDII, and Transition Relief
Recording of a 110-minute CPE webinar with Q&A
This webinar will go beyond the basics of reporting foreign transactions on the new Schedules K-2 and K-3. Our panel of international tax experts will cover how to report complex foreign transactions on these schedules, including the global intangible low-taxed income (GILTI) high-tax exclusion (HTE), Section 250 deduction for foreign derived intangible income (FDII), tiered partnerships, and other complicated foreign transactions, properly for tax practitioners working with multinational taxpayers.
Outline
- Complex K-2 and K-3 reporting
- Reporting challenges
- PFIC information for qualified electing funds
- Dual-consolidated losses
- GILTI and GILTI high-tax exclusion
- FDII
- Tiered partnerships
- Section 863(b) sales and treaty sourcing
- Other
- Other reporting matters
- Interaction with BBA
- Electronic filing requirements
- Other
- Transition relief: Revenue Procedure 2021-39
Benefits
The panel will cover these and other critical issues:
- Reporting the GILTI HTE on Schedule K-2
- Tiered partnership reporting on new Schedule K-3 and K-2
- How the Section 250 FDII deduction is reported on Schedule K-2
- Simplifying reporting of foreign tax withholding on interest and dividends
- How to qualify for transition relief under Revenue Procedure 2021-39
Faculty
Kyle Dawley, J.D., CPA
Principal, Global Tax Services
CliftonLarsonAllen
Mr. Dawley has spent a vast majority of his career focusing on the international tax needs of multinational businesses... | Read More
Mr. Dawley has spent a vast majority of his career focusing on the international tax needs of multinational businesses and individuals. Before CLA, he spent time in Big 4 accounting firms developing strategies and managing complex international business and tax projects which also included transfer pricing optomization. In addition to having expertise in international tax matters, Mr. Dawley has a deep appreciation of general business issues as he spent over a year employed in a biotech start-up company where he was tasked with running their daily operations and long-term vision. He has served clients in a wide-range of industries from both a U.S. inbound and outbound perspective.
Close
Alison N. Dougherty, CPA
Managing Member
Googolplex Tax
Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and... | Read More
Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and foreign corporations, partnerships, LLCs, individuals, and trusts. She specializes in U.S. international tax reporting and compliance with the preparation and review of the U.S. federal Forms 5471, 926, 8992, 8993, 5472, 8865, 8858, 8621, 8804, 8805, Schedules K-2 and K-3, 1116, 1118, 1042, 1042-T, 1042-S, 8832, 8833, 2555, 3520, 3520-A, 5713, 1120-F, 1040-NR, 8288, 8288-A, 8288-B, 8233, 8840, 8843, 8854, 8938, and FBAR. Ms. Dougherty has extensive experience working with U.S. businesses and individuals with outbound activities in foreign countries. She has also worked with foreign companies and nonresident individuals with inbound activities in the United States. Ms. Dougherty has significant experience with U.S. nonresident withholding tax, foreign partnership withholding tax, and FIRPTA withholding tax. She has managed U.S. tax compliance and advisory client engagements for U.S. C corporations, S corporations, partnerships, LLCs, U.S. individuals, U.S. trusts, foreign corporations, foreign partnerships, foreign LLCs, nonresident individuals, and foreign trusts.
Ms. Dougherty is a CPA and a tax attorney with more than 15 years of combined experience in public accounting, the practice of law, and corporate industry. She was previously a tax partner in a large regional public accounting firm in the Washington, DC area. Ms. Dougherty has served clients in various industries including technology, U.S. government contracting, commercial services, telecommunications, real estate, investment partnerships, commodities, high net worth individuals, and family offices. She has also served as a technical resource to other CPAs, accountants, tax professionals, public accounting firms, attorneys, and law firms.
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