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

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Conducted on Wednesday, July 6, 2022

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Course Materials

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.

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. Tax professionals and advisers must understand complex CFC rules and methods of domesticating and restructuring foreign corporations to avoid 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 outbound tax regime. 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 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 tax rules to ensure effective tax planning for U.S. taxpayers.

Listen as our panel discusses 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. CFC rules
  2. 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 a foreign corporation

Faculty

Chesman, Adam
Adam Chesman

Senior Director, International M&A Tax Services
RSM US

Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and...  |  Read More

Garcia, Rolando
Rolando Garcia, JD, CPA

Principal
Friedman

Mr. Garcia is a principal at Friedman where he leverages more than twenty years of experience to deliver clients tax...  |  Read More

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