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Repatriating Foreign-Source Income for U.S. Taxpayers: Minimizing the Tax Impact of Transferring Offshore Income and Gains

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, November 3, 2016

Recorded event now available

or call 1-800-926-7926

This course will provide corporate tax professionals and advisers with a practical guide to the challenges and strategies of repatriating foreign income. The panel will outline circumstances in which companies would choose to repatriate, detail steps to minimize tax on repatriation transactions, discuss required tax and financial reporting requirements with repatriation, and offer guidance on the likely impact on repatriation considerations of the new Section 385 regulations and other IRS initiatives to curb offshore tax deferral.


Provisions in the Internal Revenue Code provide opportunities to defer U.S. tax on foreign income and profits earned by U.S. taxpayers. However, many companies and individuals, even the largest multinational firms, will eventually need to repatriate some or all of those foreign-source earnings. This often involves a recognition event, unless the foreign-source income has been previously subject to U.S. income tax or some other deduction or another provision applies.

The tax consequences of repatriating income depend upon not only the character of the gain or income held abroad, but also the nature of the foreign entity that earned the income. Corporations, which have utilized earnings stripping strategies such as related-party debt transactions, will be faced with significant challenges due to the newly proposed and far-reaching Section 385 “debt to equity” regulations.

Tax advisers must have a thorough grasp of tax and operational consequences of repatriating foreign-source income held offshore to avoid costly tax consequences. At the same time, there are circumstances in which repatriation is necessary and even advantageous to U.S. resident multinational taxpayers. A critical skill for advisers is identifying situations in which repatriation can be accomplished in a tax-efficient manner.

Listen as our experienced panel provides a practical guide to the tax opportunities, pitfalls and strategies of repatriating foreign-source income.



  1. Deferral regime for foreign-source income and gains
  2. Impact of foreign entity classification on repatriation treatment
  3. Identifying deductions and calculating income on repatriation events
  4. Strategies for minimizing tax impact of repatriating foreign-source income
  5. Impact of proposed Section 385 regulations


The panel will discuss these and other important issues:

  • Creating a repatriation strategy
  • Impact of Section 385 proposed regulations on earnings stripping intra-company debt strategies
  • Identifying deductions and credits which would reduce taxable income on repatriation
  • Repatriation issues for individual and small business taxpayers


Morgan, Chip
Chip Morgan, JD

International Tax Partner

Mr. Morgan has focused his career on international tax for over 30 years. He has been an international tax services...  |  Read More

Albert W. Liguori
Albert W. Liguori

Managing Director
Alvarez & Marsal Taxand

With more than 20 years of international tax and accounting experience, Mr. Liguori assists multinational...  |  Read More

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