Foreign Personal Holding Company Income Reporting: Mastering Subpart F Inclusions and Deemed Dividend Rules
Navigating Foreign Tax Credit Passive Buckets, Look-Through Recharacterizations, and More
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a deep exploration of the reporting of income from and ownership of a foreign personal holding company. The panel will identify the tests for determining whether an investment qualifies as a FPHC, outline what qualifies as foreign personal holding company income (FPHCI), discuss attribution and constructive ownership rules, and offer useful tools for minimizing and reporting FPHCI.
- Identifying FPHCI through ownership and income tests
- Indirect ownership
- Ownership attribution rules
- Treaty exclusions from gross income calculations
- Reporting FPHC holdings and income
- Treatment of undistributed FPHCI
- Look-through provisions on distributions from related entities
- Calculating foreign tax credit “buckets” for FPHCI
The panel will discuss these and other important questions:
- What passive activities qualify for exclusion from FPHCI calculations?
- How do the look-through rules operate to recharacterize certain dividend payments?
- What is the reporting treatment of the sale of FPHC ownership interests?
- How do the attribution rules function in determining ownership of an FPHC interest?
Harlowe & Falk
Mr. Ghassemieh's practice focuses on assisting companies of all sizes, in all business and tax matters,... | Read More
Mr. Ghassemieh's practice focuses on assisting companies of all sizes, in all business and tax matters, including advising closely held businesses to establish new business entities, advising on regulatory and tax matters, succession planning, and tax efficient planning for purchases or sales of existing businesses. He also provides tax consulting services to clients with international operations. His clients include both U.S.–based companies that have expanded abroad and foreign companies with U.S. ties. He also consults with U.S.–based exporting companies to determine whether they qualify for IC–DISC tax incentive benefits, and assists in both implementation and maintenance of IC–DISC structures.Close
William R. Skinner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.Close
David N. de Ruig
Fenwick & West
Mr. de Ruig focuses his practice on a broad variety of domestic and international tax matters in the high... | Read More
Mr. de Ruig focuses his practice on a broad variety of domestic and international tax matters in the high technology and life sciences industries. He also represents clients in tax controversy matters. Previously he was a tax associate with Morrison & Foerster LLP in New York.Close