Domesticating Individually Owned Controlled Foreign Corporations Under Current Tax Law
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
This course will guide tax professionals and advisers on the legal challenges and available planning techniques for domesticating individually owned controlled foreign corporations (CFCs) under current tax law. 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.
- Tax reform changes to CFC rules
- Recent IRS regulations and guidance for individual and pass-through shareholders
- Domestication and restructuring strategies of CFCs for U.S. taxpayers
- 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
Jill Boland, JD, LLM
Ms. Boland's areas are inbound/outbound international transactions involving C corporations, partnerships, and... | Read More
Ms. Boland's areas are inbound/outbound international transactions involving C corporations, partnerships, and indivudals. She has experience with issues surrounding foreign tax credits, corporate restructuring, subpart F income, and permanent establishment.Close
Rolando Garcia, JD, CPA
Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for... | Read More
Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for international individuals and businesses, identifying international tax incentives and advising multinational businesses on establishing a U.S. presence. Additionally, he is heavily relied on by his clients to navigate inbound and outbound practices, including pre-immigration planning for individuals, and more.Close