GILTI Calculations for Individual U.S. Shareholders in CFCs: GILTI High-Tax Exclusion and Sec. 962 Elections
Subpart F Controlled Foreign Corporation Treatment, Recognizing QBAI, and Section 951A Tax on Foreign Intangible 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 a practical guide to the global intangible low-taxed income (GILTI) provisions for U.S. shareholders in controlled foreign corporations (CFCs). 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 individual U.S. shareholders, including electing the GILTI high-tax exclusion under the recent final regulations.
- Section 951A overview
- Final GILTI high-tax exclusion
- Section 962 election
- GILTI high-tax exclusion vs. Section 962 election
- Planning opportunities for individuals to minimize the tax impact of GILTI
The panel will review these and other essential matters:
- When an individual is subject to tax under IRC 951A
- Determining a U.S shareholder's pro-rata share of CFC tested items
- When electing the GILTI high-tax exclusion can benefit a U.S. shareholder
- When making the Section 962 election can benefit a U.S. shareholder
- Pros and Cons of the GILTI high-tax exclusion versus the Section 962 election
Sean Dokko, J.D., LL.M.
Managing Director, National Tax Office - International Tax Services
Mr. Dokko focuses on international tax planning and consulting for both inbound and outbound clients. He has experience... | Read More
Mr. Dokko focuses on international tax planning and consulting for both inbound and outbound clients. He has experience in structuring and implementing tax efficient foreign holding company structures, IP migrations, cross border restructurings, foreign tax credit planning, implementing strategies to minimize subpart F income, and analyzing income tax treaties. In addition, Mr. Dokko is responsible for analyzing and addressing technical issues related to the various international tax provisions that were included as part of the Tax Cuts and Jobs Act such as the Section 965 transition tax, global intangible low-taxed income and the associated Section 250 deduction, the Section 250 deduction for foreign derived intangible income, and the base erosion and anti-abuse tax. As part of the National Tax Office, he is responsible for assisting the firm’s offices with analyzing complex international tax issues and reviewing international tax technical advice provided to the firm’s clients.Close
Ms. Krueger has been a member of the International Tax consulting group for more than 10 years. She consults on both... | Read More
Ms. Krueger has been a member of the International Tax consulting group for more than 10 years. She consults on both inbound and outbound cross-border tax planning for public and privately-held companies.Close
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