Domesticating Individually-Owned Controlled Foreign Corporations Post-Tax Reform

Restructuring CFCs for U.S. Taxpayers, Mitigating Tax Liability, Section 962 Election, Transition Tax

Recording of a 90-minute premium CLE/CPE webinar with Q&A

Conducted on Thursday, June 20, 2019

Recorded event now available

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Program Materials

This webinar will provide guidance to tax professionals and advisers on the legal challenges and available planning techniques for domesticating individually-owned controlled foreign corporations (CFCs) post-tax reform. The panel will discuss rules governing U.S. persons with non-U.S. businesses and investments, the impact of tax reform on non-corporate U.S. shareholders of foreign corporations, methods in mitigating increased tax liability, Section 962 elections, and the application of Section 965 for purposes of domestication of a foreign corporation.


U.S. tax reform significantly changed the rules governing U.S. persons with non-U.S. businesses and investments. Non-corporate U.S. shareholders of foreign corporations are subject to increased taxes, and tax professionals and advisers must understand complex new CFC rules and methods of domesticating and restructuring foreign corporations to avoid any unforeseen tax liability.

U.S. individuals, trusts and non-corporate shareholders of foreign corporations can limit, or in some cases avoid, the impact of the new outbound tax regime. New U.S. tax law provides complex provisions targeting U.S. multinationals doing business abroad, such as the transition tax on deferred foreign income, GILTI and other regulations impacting U.S. shareholders of foreign corporations. Domesticating or restructuring CFCs can limit the impact of the new tax regime and provide tax savings for U.S. taxpayers.

Tax professionals and advisers must reexam existing structures of foreign corporations owned by U.S. shareholders and understand the application of new tax rules to ensure effective tax planning for U.S. taxpayers.

Listen as our panel discusses new tax rules governing U.S. persons and non-corporate shareholders with non-U.S. businesses and investments and the legal challenges and available planning techniques for domesticating individually-owned CFCs post-tax reform.



  1. Tax reform changes to CFC rules
  2. Recent IRS regulations and guidance for individual and pass-through shareholders
  3. Domestication and restructuring strategies of CFCs for U.S. taxpayers
  4. Best practices to minimize unforeseen tax liability


The panel will discuss these and other key issues:

  • How does tax reform impact rules governing U.S. persons with non-U.S. businesses and investments?
  • What factors must be considered by non-corporate U.S. shareholders of foreign corporations?
  • What methods are available for domesticating or restructuring CFCs for U.S. taxpayers?
  • How can Section 962 elections ensure tax savings?
  • Application of the transition tax and GILTI for purposes of domesticating of a foreign corporation


Brunoro-Borokhov, Paula
Paula Brunoro-Borokhov

Brunoro Law

Ms. Brunoro-Borokhov’s practice is focused on assisting businesses and individuals with business and tax related...  |  Read More

Skinner, William
William R. Skinner

Fenwick & West

Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and...  |  Read More

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