GILTI High-Tax Exclusion: Sections 951A and 954 Rules for Individual and Non-C Corporation CFC Shareholders
Treatment of CFC income, Reporting Requirements, Planning Techniques to Defer or Reduce GILTI Tax, and More
Recording of a 90-minute premium CLE/CPE video webinar with 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 non-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. non-C corporation 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
W. Aaron Hawthorne
Principal
RSM US
Mr. Hawthorne is a Principal at RSM US LLP Dallas Private Client Services Leader Houston International... | Read More
Mr. Hawthorne is a Principal at RSM US LLP Dallas Private Client Services Leader Houston International Private Client Services Leader. He advises successful individuals and families. Providing resolution of complex financial issues to protect and grow wealth, particularly in the income tax, gift tax, estate tax, generation-skipping tax and investment areas, including multi-national issues for those entering or leaving the United States. He specializes in tax planning and structuring to properly limit tax implications for families over multiple generations.
Close
Trang Phan
Senior Managing Director, Tax Services
RSM US
Ms. Phan focuses on cross-border tax planning strategies and tax reporting and compliance for multinational companies... | Read More
Ms. Phan focuses on cross-border tax planning strategies and tax reporting and compliance for multinational companies and the private equity markets. She has 17 years of public accounting experience with both the Big Four and middle market firms in the international arena. Ms. Phan provides consulting and compliance support on a broad range of issues across different industries, including private equity, manufacturing, technology and real estate. She regularly assists clients with the design and implementation of various tax-efficient structures in different geographic regions.
Close
Adam Chesman
Senior Director, International M&A Tax Services
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.
Close