Outbound Transactions and U.S. Federal Tax
Tackling Compliance Challenges for U.S. Companies With Foreign-Based Income or Business Relationships
Recording of a 110-minute CPE webinar with Q&A
This teleconference will give corporate tax professionals and advisors a review of essential federal tax issues affecting outbound transactions and explore difficult aspects that frequently arise in preparing related IRS forms.
Overview of key concepts
- Worldwide income and foreign tax credits
- Entity structures
- CFCs and Subpart F
- Re-organizations and asset transfers
- Anti-inversion rules
- Tax treaties
Issues to anticipate U.S. forms and schedules
- Form 5471
- Form 926
- Form 8865
- Form 8895
The panel will address these and other topics that have a material impact on outbound transactions forms compliance:
- Tax implications of choice of entity and check-the-box regulations for U.S.-owned foreign companies.
- The "control" standard for foreign entity ownership.
- Controlled foreign corporation restructuring and the tax impact of asset transfers outside the U.S.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
He works with business and individual clients on a broad range of tax planning and controversy engagements, including... | Read More
He works with business and individual clients on a broad range of tax planning and controversy engagements, including international tax compliance along with associated voluntary disclosures and planning.Close
Melinda Fellner Bramwit
Norris McLaughlin & Marcus
Ms. Bramwit's practice emphasizes federal, state and international tax planning and transactions, particularly in... | Read More
Ms. Bramwit's practice emphasizes federal, state and international tax planning and transactions, particularly in regard to corporate acquisitions. She routinely represents clients in federal and state tax controversies and on IRS offshore voluntary compliance participation.Close
Wilkin & Guttenplan
He works primarily with high-tech, software and other closely held businesses on U.S. taxation of international... | Read More
He works primarily with high-tech, software and other closely held businesses on U.S. taxation of international business, income tax planning and compliance matters. He previously worked on tax research services for the AICPA.Close