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.
- 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
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?
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
Pamela A. Fuller, Esq., J.D., LL.M. (Taxation)
Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Group
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide... | Read More
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide range of clients–including private and public companies, joint ventures, funds, high-net-worth individuals, C-Suite executives, and government entities–on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. Ms. Fuller advises clients on both purely domestic transactions and transnational ones, helping both U.S.-based companies and foreign companies (and their executives) achieve the best possible results from a tax and business perspective. Ms. Fuller is Chair of the ABA’s Tax Section’s Tax Policy Committee, and also Co-Chair of the International Tax Committee of the ABA’s worldwide International Law Section. She frequently speaks at law conferences, and publishes papers on international tax topics in peer-reviewed law journals.Close
Access Anytime, Anywhere
CPE credit is not available on downloads.