Section 965 Foreign Deemed Repatriation Transition Tax: Final Regulations
Identifying Cash Positions, Treatment of Consolidated Entities, Loss Treatments, Correcting Underpayments, Anti-Avoidance Rules
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide corporate tax advisers with a detailed and practical guide to the repatriation provisions of the Section 965 transition tax in the wake of the most recent IRS final regulatory guidance. The panel will discuss E&P and basis adjustments, foreign tax credit calculations, and special rules governing affiliated groups and consolidated returns.
- Shareholders subject to new foreign provisions
- Definition of "specified foreign corporations"
- Identifying and calculating accumulated E&P subject to deemed repatriation transition tax
- Netting provisions
- Calculating tax
- Section 965(h) elections
- IRS guidance finalized in January 2019 and adjustments to prior proposed regulations
- Consolidated return provisions
- Exemptions to cash positions
- Anti-avoidance rule application
- Fiscal year taxpayers with initial payments due in 2019
The panel will review these and other key issues:
- Determining the applicability of Section 965 to specific U.S. shareholders
- Identifying what is cash vs. non-cash for purposes of foreign-source income and applicable tax rates
- The use of NOLs and determining taxable foreign-source income
- New guidance governing consolidated returns and loss allocations
- Application of anti-avoidance rules to E&P reducing transactions
Mary Beth Lougen, EA, USTCP
Chief Operating Officer
Expat Tax Tools
As an exceptional researcher, Ms. Lougen constantly monitors the ever changing US tax law and regulations to keep her... | Read More
As an exceptional researcher, Ms. Lougen constantly monitors the ever changing US tax law and regulations to keep her team abreast of the latest developments enabling a broader understanding of international taxation, domestic taxation, and tax treaty interpretation. Her progressive experience in US international taxation and reporting, coupled with her hands on leadership is a proven combination to provide clients with a confidence that their tax needs are being met with professionalism and integrity.Close
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