GILTI High-Tax Exclusion: Sections 951A and 954 Rules for Individual and C Corporation Shareholders
Treatment of CFC income, Reporting Requirements, Planning Techniques to Defer or Reduce GILTI Tax, and More
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE course will guide tax professionals on the challenges of the global intangible low-taxed income (GILTI) provisions under current tax law and the recent GILTI high-tax exception. The panel will discuss IRS final regulations and the high-tax exception, treatment of controlled foreign corporation (CFC) income, and reporting requirements for individual and C corporation taxpayers subject to GILTI, as well as provide tax planning tips to minimize the tax liability of taxpayers with CFC interests.
Outline
- Overview of Section 951A
- Prior treatment of CFC income and reporting requirements
- C corporation vs. Individual taxpayers and the application of GILTI rules
- GILTI high-tax exclusion
- Methods to defer or reduce the impact of GILTI for individuals, trusts, and non-C corporation U.S. shareholders
Benefits
The panel will review these and other relevant topics:
- Determining whether a taxpayer is subject to GILTI tax under Section 951A
- Calculating GILTI on CFC income
- GILTI high-tax exclusion
- Recognizing the reporting requirements and possible credits or deductions
- Tactics to defer or minimize the GILTI tax
Faculty
Adam Chesman
Senior Director, Cross-Border Mergers and Acquisitions Tax Leader
RSM US
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.
CloseSam Heberton
Senior Tax Manager - International Tax
Bennett Thrasher
Mr. Heberton is a Senior Tax Manager in Bennett Thrasher’s Tax practice, focusing primarily on income tax... | Read More
Mr. Heberton is a Senior Tax Manager in Bennett Thrasher’s Tax practice, focusing primarily on income tax services and tax planning services for international taxpayers.He has experience in public accounting, including Big 4 experience; experience with business entities in the telecom, real estate, retail, manufacturing & distribution, SaaS, healthcare, and the professional services industries; and experience with US individuals and expatriates.
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Early Discount (through 11/15/24)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.