Structuring Private Equity for GILTI and Subpart F: Minimizing Tax for CFCs Under Section 951A, Final Regulations
Note: CPE credit is not offered on this program
Recording of a 90-minute premium CLE video webinar with Q&A
This CLE course will examine the Subpart F and global intangible low-taxed income (GILTI) rules regarding taxation of controlled foreign corporation (CFC) income and how those rules impact the structuring of private equity investments and funds. The panel will also discuss new regulations that offer clarity and some relief to non-corporate CFC shareholders.
Outline
- Taxation of CFCs pre-2017 tax reform
- Subpart F
- Section 951A and GILTI: impact on CFCs
- New regs: implications for private equity investors
- Planning opportunities to minimize tax on foreign holdings
Benefits
The panel will review these and other relevant topics:
- What is a CFC, and what does Subpart F say about taxation of CFC passive income?
- Why should private equity investors be concerned with the GILTI tax under Section 951A?
- How is GILTI calculated on CFC income?
- How have the new regs improved the tax position for private equity investors, and what kind of investment structures should now be employed?
Faculty
Eytan Burstein, CPA
International Tax Director
CohnReznick
Mr. Burstein has more than 13 years of experience providing international tax services to clients in a wide range of... | Read More
Mr. Burstein has more than 13 years of experience providing international tax services to clients in a wide range of industries, including technology and life sciences, real estate, and consumer products. He has specific expertise in advising U.S. multinational companies and private equity firms on cross-border transactions, including cash repatriation planning, foreign tax credit analysis, global effective tax rate planning, and U.S. anti-deferral rules. Mr. Burstein also provides tax services to inbound investors, including acquisition structuring, permanent establishment analysis, and withholding rules. Additionally, Mr. Burstein assists companies and individuals with any required international tax reporting as part of their annual tax return filings and international tax components of annual financial statements. He has also guided U.S. companies and individuals in understanding the international tax components of the tax reform legislation passed in 2017.
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Bradley Mainguy, JD, LLM
Principal
CohnReznick
Mr. Mainguy has more than eight years of public accounting experience providing international tax services to clients... | Read More
Mr. Mainguy has more than eight years of public accounting experience providing international tax services to clients in a wide range of industries, as well as individuals and publicly traded companies. He has extensive experience working with multinational corporate clients on consulting and compliance projects, including global business model optimization and restructuring projects from the design and feasibility stage through implementation. He also has expertise in U.S. tax issues relating to both inbound and outbound investments, as well as navigating the increasingly complex network of reporting, disclosure, and withholding requirements arising from doing business in a global economy.
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Gerald Rokoff
Partner; Co-Chair, Transactional Tax Practice
DLA Piper
Mr. Rokoff has more than 35 years of experience in global and U.S. tax matters, helping clients ensure maximum... | Read More
Mr. Rokoff has more than 35 years of experience in global and U.S. tax matters, helping clients ensure maximum financial benefit and optimum tax treatment. He has extensive experience in advising fund sponsors, investment advisors and investors in identifying and implementing tax-efficient structures worldwide to enhance after-tax yield for the investors and advisors. Mr. Rokoff has structured investments for U.S. and non-U.S. investors across a broad base of asset classes including real estate, debt and equities, operating businesses and alternative investments. In addition, he works with private equity funds and regulated investment companies that are active in the insurance sector and regularly advise them on their investments and ongoing operations.
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