New Subpart F and PFIC Regulations for U.S. Investors and Domestic Funds
Calculating Subpart F and PFIC Inclusions, Partner-Level PFIC Elections, IRC Sec. 1248, CFC and PFIC Overlap Rules
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers guidance on recently released final and proposed regulations for calculating Subpart F and passive foreign investment company (PFIC) inclusions. The panel will discuss key provisions of the final and proposed rules, the impact to U.S. investors who own interests in foreign corporations through domestic partnerships, changes to Subpart F inclusion rules, proposed partner-level PFIC elections, IRC Sec. 1248 treatment of domestic partnerships, controlled foreign corporation (CFC) and PFIC overlap rules, and other key issues.
Outline
- Final Subpart F regulations
- Key components of Subpart F anti-deferral regime
- Determining Subpart F income
- Reporting Subpart F income on Form 5471
- Best practices for ensuring accurate reporting of Subpart F income
- Proposed PFIC regulations
- PFIC treatment, purging, and deemed distribution rules
- Reporting requirements and inclusions
- Main issues and pitfalls to avoid in reporting and preparing required tax forms
Benefits
The panel will review these and other key issues:
- What are the tax compliance challenges for U.S. persons owning CFCs?
- What are the key provisions and challenges of the final Subpart F and proposed PFIC rules?
- What are the challenges in determining and calculating Subpart F and PFIC income?
- What are the main issues and pitfalls to avoid in reporting and preparing the required tax forms?
Faculty
Catherine Daly
Managing Director
Ernst & Young
Ms. Daly specializes in international taxation, particularly US tax reporting for large Wealth and Asset Management and... | Read More
Ms. Daly specializes in international taxation, particularly US tax reporting for large Wealth and Asset Management and Banking clients.
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John C. Owsley
Senior Manager, International Tax and Transaction Services
Ernst & Young
Mr. Owsley has experience in advising companies with regard to their international tax issues. He works with companies... | Read More
Mr. Owsley has experience in advising companies with regard to their international tax issues. He works with companies providing advisory, planning, structuring and transactional services to U.S. multinationals with international operations and foreign multinationals with U.S. operations. Mr. Owsley advises on structuring domestic and international reorganizations, cross-border financing, debt structuring, mergers and acquisitions, PFICs and anti-deferral regimes.
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Stephen M. Peng
Managing Director
Ernst & Young
Prior to joining EY, Mr. Peng was a tax attorney at the IRS Office of Associate Chief Counsel (International) focused... | Read More
Prior to joining EY, Mr. Peng was a tax attorney at the IRS Office of Associate Chief Counsel (International) focused on subpart F, PFIC, FTC, treaty, and inbound matters. He was an international tax manager with another Big4 firm and an associate tax attorney with an international law firm in Washington, DC prior to his time at the IRS.
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