Mastering Subpart F Tax Compliance: Key Reporting Requirements on Forms 5471 and 1118

Recording of a 90-minute premium CLE/CPE webinar with Q&A

Conducted on Thursday, December 3, 2020

Recorded event now available

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Course Materials

This CLE/CPE course will provide tax professionals an in-depth discussion of the challenges of reporting Subpart F income. The panelist will discuss the proper methods of determining the Subpart F income earned by U.S. persons that qualify as U.S. shareholders of controlled foreign corporations (CFCs) and how to report such Subpart F income. The panelist will assist tax pros in navigating Forms 5471 and 1118 and will discuss tax planning techniques to minimize tax liability and penalties.


The Subpart F rules require U.S. shareholders of CFCs to treat certain types of foreign corporate income as taxable in the current year. The changes wrought by the TCJA to the Subpart F rules increase the number of foreign corporations that are treated as CFCs and caught many more U.S. persons in the Subpart F net. Tax professionals must recognize the resulting U.S. foreign tax information reporting challenges for U.S. persons owning foreign corporations and need to expand their Subpart F expertise so that they can effectively navigate the two most relevant Subpart F reporting platforms: Form 5471 and Form 1118.

The panel will also compare and contrast Subpart F with the GILTI anti- deferral regime. Post–TCJA, because of the TCJA’s introduction of the GILTI anti- deferral regime, a U.S. shareholder of a CFC may even wish to trigger Subpart F income to get out of the GILTI rules because Subpart F income is subject to less stringent U.S. foreign tax credit strictures than GILTI.

Listen as Khiem Ting, Senior Manager / Director at KPMG, reviews the Subpart F rules and provides a practical guide to determining CFC ownership, Subpart F income and reporting obligations for U.S. shareholders of CFCs with Subpart F income.



  1. Basic components of the Subpart F anti – deferral regime
  2. Determining Subpart F income
  3. Reporting Subpart F income on Form 5471
  4. Claiming the foreign tax credit for Subpart F income on Form 1118
  5. Best practices for ensuring accurate reporting of Subpart F income


The panelist will review these and other key issues:

  • What are the tax compliance challenges for U.S. persons owning controlled foreign corporations?
  • How has the application of Subpart F expanded post - TCJA?
  • What are the challenges in determining and calculating Subpart F income?
  • What are the main issues and pitfalls to avoid in preparing Forms 5471 and 1118?


Ting, Khiem
Khiem Ting
Senior Manager / Director

Mr. Ting provides US international tax services to a broad range of clients including US and foreign multinational...  |  Read More

Rhee, Stephen
Stephen Rhee

Senior Associate


 |  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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