Foreign Branches, QBUs, and Disregarded Entities: Foreign Tax Credits, Anti-Hybrid Rules, and Planning Strategies
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will explain foreign branches' tax considerations, including what constitutes a foreign branch and its U.S. reporting obligations, calculating foreign branch income and the related foreign tax credit, and the recent 267A anti-hybrid regulations.
Outline
- Foreign branches - Overview
- Foreign branch loss recapture under Section 91
- Subpart F and GILTI
- Section 954 (d)(2) branch income rules
- GILTI and Subpart F high-tax exceptions
- Foreign tax credit
- Anti-Hybrid rules
- Form 8858 reporting
- Planning strategies
Benefits
The panel will review these and other critical issues:
- What constitutes a foreign branch?
- Who is required to file Form 8858 and Schedule M?
- What is a branch mismatch payment under Section 267A?
- What are the differences between a foreign subsidiary and a foreign branch?
Faculty
Adam Chesman
Senior Director, Cross-Border Mergers and Acquisitions Tax Leader
RSM US
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.
ClosePamela A. Fuller, Esq., J.D., LL.M. (Taxation)
Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Group
Ms. Fuller is a corporate and international tax attorney with over 20 years experience in advising a wide range of... | Read More
Ms. Fuller is a corporate and international tax attorney with over 20 years experience in advising a wide range of clients -- including private clients and companies, joint ventures, private equity funds, HNW indviduals, C-Suite executives, "start-ups," and government entities -- on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. She has deep expertise in structuring cross-border M&A transactions, and advising mobile international families. Her clients hail from a multitude of industries, including the burgeoning world of decentralized finance (DeFi). Pamela is also a seasoned taxpayer advocate, with decades of experience resolving complex U.S. federal, state, and foreign tax controversies.
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CPE credit is not available on downloads.
CPE On-Demand