New 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

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

Thursday, October 22, 2020

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

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This CLE/CPE webinar will provide tax professionals with guidance 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.

Description

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, as it generally consists of all 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 when 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 shine a light on aspects of the GILTI high-tax exclusion and conforming them with the Subpart F high-tax exception. They also provide for an election under Sec. 954(b)(4) for purposes of 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.

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Outline

  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. New GILTI high-tax exclusion
  5. 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
  • New GILTI high-tax exclusion
  • Recognizing the reporting requirements and possible credits or deductions
  • Tactics to defer or minimize the GILTI tax

Faculty

Granwell, Alan
Alan Winston Granwell
Of Counsel
Holland & Knight

Mr. Granwell has been practicing in international taxation for more than 45 years and previously was director of the...  |  Read More

Additional faculty
to be announced.

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