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 video 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.
- CFC rules
- 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 a foreign corporation
Senior Director, International M&A Tax Services
Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and... | Read More
Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and audit, with particular emphasis on structuring domestic and cross-border mergers and acquisitions, spin-off transactions, post-merger integrations, debt restructurings, bankruptcy workouts, and application of the consolidated return regulations.Close
Rolando Garcia, JD, CPA
Mr. Garcia is a principal at Friedman where he leverages more than twenty years of experience to deliver clients tax... | Read More
Mr. Garcia is a principal at Friedman where he leverages more than twenty years of experience to deliver clients tax services that moves them closer to their goals. He represents individuals, closely held businesses, trusts, family offices, and international interests in virtually all industries. Mr. Garcia counsel clients concerning federal state and local, domestic U.S. and foreign tax regimes, tax planning and compliance, and special situations.Close