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


Conducted on Thursday, May 28, 2020

Recorded event now available

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Program Materials

This webinar 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.

Description

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 reexamine 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 under current tax law.

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Outline

  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

Benefits

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

Faculty

Boland, Jill
Jill Boland, JD, LLM

Director
CliftonLarsonAllen

Ms. Boland's areas are inbound/outbound international transactions involving C corporations, partnerships, and...  |  Read More

Garcia, Rolando
Rolando Garcia, JD, CPA

Shareholder
Doeren Mayhew

Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for...  |  Read More

Other Formats
— Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video

48 hours after event

$347

Download

48 hours after event

CPE Not Available

$347

DVD

10 business days after event

CPE Not Available

$347 + $24.45 S&H