Section 951A: GILTI 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

Recording of a 90-minute premium CLE/CPE webinar with Q&A

Conducted on Tuesday, July 16, 2019

Recorded event now available

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Program Materials

This CLE/CPE webinar will provide tax professionals with guidance on the challenges of the global intangible low-taxed income (GILTI) provisions under the new tax bill. The panel will discuss treatment of controlled foreign corporation (CFC) income, reporting requirements for individual and non-C corporation taxpayers subject to GILTI, and provide tax planning tips to minimize the tax liability of taxpayers with CFC interests. The panel will also discuss recent Treasury and IRS regulations issued in June of 2019 regarding GILTI and Subpart F income.


Tax reform significantly expanded the application of Subpart F and added a new inclusion rule for controlled foreign corporation (CFC) income, the global intangible low-taxed income (GILTI) rule.

GILTI is not limited to intangible nor low-taxed income, as it generally consists of all of a CFC's net income, less subpart F income, a 10% return on depreciable tangible assets, and a few other exclusions. A U.S. person who is a shareholder owning at least 10% of a CFC is subject to U.S. federal income tax on a share of the CFC's GILTI under new IRC Section 951A. Individuals can experience higher tax rates on GILTI when compared to domestic C corporations.

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.



  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. Methods to defer or reduce the impact of GILTI for individuals, trusts and non-C corporation U.S. shareholders


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
  • Recognizing the reporting requirements and possible credits or deductions
  • Tactics to defer or minimize the GILTI tax


Grossman, Cindy
Cindy L Grossman

Giordani Baker Grossman & Ripp

Ms. Grossman’s practice encompasses a wide variety of corporate and partnership transactions with international,...  |  Read More

Zhang, Libin
Libin Zhang

Fried Frank Harris Shriver & Jacobson

Mr. Zhang is a tax partner in Fried Frank's New York office. Prior to joining the firm in 2019, he was a tax...  |  Read More

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