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

A live 90-minute premium CLE/CPE webinar with interactive Q&A

Thursday, December 3, 2020

1:00pm-2:30pm EST, 10:00am-11:30am PST

Early Registration Discount Deadline, Friday, November 6, 2020

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This CLE/CPE webinar will provide tax professionals an in-depth discussion of the challenges of reporting Subpart F income. The panel 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 panel will assist tax pros in navigating Forms 5471 and 1118 and will discuss tax planning techniques to minimize tax liability and penalties.

Description

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 our authoritative panel of international tax practitioners 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.

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Outline

  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

Benefits

The panel 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?

Faculty

Ting, Khiem
Khiem Ting
Senior Director
KPMG

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

Additional faculty
to be announced.

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