GILTI Calculations for Individual CFC Shareholders: Section 951A Tax on Foreign Intangible Income
Changes to Subpart F Controlled Foreign Corporation Treatment, Recognizing QBAI, and More
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This course will provide tax advisers with a practical guide to the tax reform bill's global intangible low-taxed income (GILTI) provisions. The panel will detail the tax calculations and reporting requirements for taxpayers with GILTI inclusions and describe planning opportunities to minimize the tax impact on individuals with GILTI inclusions.
- Section 951A overview
- Calculating GILTI
- Treatment of domestic partnerships and their partners
- Planning opportunities for individuals to minimize the tax impact of GILTI
- GILTI high tax exclusion
- Build Back Better changes
The panel will review these and other essential matters:
- When an individual is subject to tax under IRC 951A
- Calculating QBAI
- Determining a U.S. shareholder's pro-rata share of CFC tested items
- The application of GILTI to domestic partnerships and their partners
- The benefits and cons to a Section 962 election
Sean Dokko, J.D., LL.M.
Principal, Head of Tax
Mr. Dokko advises clients on U.S. international tax matters with a focus on inbound and outbound tax planning and... | Read More
Mr. Dokko advises clients on U.S. international tax matters with a focus on inbound and outbound tax planning and consulting. He has extensive experience in developing, implementing, and reporting tax planning strategies and cross-border restructurings.Close
Fried Frank Harris Shriver & Jacobson
Mr. Zhang is a tax partner in Fried Frank's New York office. Prior to joining the firm in 2019, he was a tax... | Read More
Mr. Zhang is a tax partner in Fried Frank's New York office. Prior to joining the firm in 2019, he was a tax partner at Roberts & Holland LLP. He works on a diverse range of real estate, corporate, and international taxation matters. He represents real estate investment trusts (REITs) and other companies on tax-free reorganizations, spin-offs, cross-border joint ventures, complex leases, and other tax-efficient transactions. He also advises clients about tax credits, state and local transfer taxes, and qualified opportunity zones.Close
Early Discount (through 02/25/22)
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.