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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

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Conducted on Wednesday, December 7, 2022

Recorded event now available

or call 1-800-926-7926

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, reporting requirements for individual and non-C corporation taxpayers subject to GILTI, and provide tax planning tips to minimize the tax liability of taxpayers with CFC interests.


Tax reform significantly expanded the application of Subpart F and added a new inclusion rule for CFC income--the GILTI rule.

GILTI is not limited to intangible or low-taxed income. It generally consists of a CFC's net income, less Subpart F income, a 10 percent return on depreciable tangible assets, and a few other exclusions. A U.S. person who is a shareholder owning at least 10 percent of a CFC is subject to U.S. federal income tax on a share of the CFC's GILTI under IRC Section 951A. Individuals can experience higher tax rates on GILTI compared to domestic C corporations.

Also, the IRS recently issued regulations to address the treatment of income subject to high foreign tax rates. The regulations highlight aspects of the GILTI high-tax exclusion and conform them with the Subpart F high-tax exception. They also provide for an election under Sec. 954(b)(4) for both Subpart F income and tested income.

Listen as our panel provides tax professionals with guidance on the challenges of the GILTI provisions under the new tax law. The panel will discuss GILTI and the Section 250 deduction--particularly for individual taxpayers--and provide tax planning tips to minimize the tax liability of taxpayers with CFC interests.



  1. Overview of Section 951A
  2. Prior treatment of CFC income and reporting requirements
  3. C corporation vs. non-C corporation and the application of GILTI rules
  4. GILTI high-tax exclusion
  5. Methods to defer or reduce the impact of GILTI for individuals, trusts, and non-C corporation U.S. shareholders


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


Chesman, Adam
Adam Chesman

Senior Director, Cross-Border Mergers and Acquisitions Tax Leader

Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and...  |  Read More

Heberton, Sam
Sam 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

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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