Form 8832 Check-the-Box Entity Elections Under Section 7701: Selecting Entities for Foreign Operations
Using Hybrid Entities for Tax Arbitrage to Lower U.S. Tax on Eligible Foreign Income
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide tax advisers with practical guidance on the advantages and pitfalls of utilizing the "check-the-box" entity selection for U.S. individuals with offshore business activities. The panel will discuss the various tax effects of specific elections, outline the tax timing and tax treatment, and explain repatriation and other implications of income from foreign subsidiaries under the 2017 tax reform legislation.
- Basic entity classification rules for foreign entities owned by U.S. individuals
- Determination of when a foreign entity is “relevant” for U.S. income tax and information reporting purposes
- Evaluating tax consequences as part of entity selection determination
- Overview of Subpart F rules
- GILTI regime
- Section 962 election by an individual
- Distributions and sales of CFC stock under different entity models
- Review of provisions related to U.S. "territorial regime"
- Entity selection process and available elections
- Completing Form 8832
The panel will discuss these and other important issues:
- The implications of using check-the-box elections to pull foreign-source income out of Subpart F treatment
- Retroactive entity selection and completing Form 8832
- How to determine whether a foreign entity is "relevant" for U.S. taxation purposes
- The impact of tax law changes on check-the-box elections and tactics to maximize tax savings
Alison N. Dougherty, J.D., LL.M.
Director, Tax Services
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a... | Read More
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.Close
Pamela A. Fuller, JD, LLM
Tully Rinckey PLLC & Royse Law
Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity... | Read More
Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity funds, individuals, C-Suite executives, “start-ups,” and government entities--on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. As a seasoned practitioner and tax technician, Ms. Fuller is accustomed to handling nuanced matters involving highly technical questions of law, policy, and procedure at the federal, state, local, and international levels. She provides sophisticated tax planning services across most industry sectors, including software & emerging digital technologies, financial services, real estate development, healthcare, pharmaceutical, construction & engineering, infrastructure, oil & energy, and retail.Close
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