Structuring Private Equity for GILTI and Subpart F: Minimizing Tax for CFCs Under Section 951A, New Regulations
Note: CPE credit is not offered on this program
A live 90-minute premium CLE webinar with interactive Q&A
This CLE webinar 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 which offer clarity and some relief to non-corporate CFC shareholders.
- Taxation of CFCs pre-2017 tax reform
- Subpart F
- Section 951A and GILTI--impact on CFCs
- New regs: iimplications for private equity investors
- Planning opportunities to minimize tax on foreign holdings
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?
International Tax Senior Manager
Mr. Robins is the international tax and transfer pricing practice leader in Grant Thornton LLP’s Philadelphia... | Read More
Mr. Robins is the international tax and transfer pricing practice leader in Grant Thornton LLP’s Philadelphia office. His international tax and transfer pricing practice consists of degreed and licensed professionals within complementary focus areas of accounting, law, and economics in delivering the most comprehensive and solution-oriented international tax services in the Philadelphia market for all types of domestic and foreign taxpayers.Close
Practice Leader, International Tax
Mr. Terzian is a partner based in the Manhattan office and serves as the East Region International Tax practice leader.... | Read More
Mr. Terzian is a partner based in the Manhattan office and serves as the East Region International Tax practice leader. He has more than 17 years of experience advising some of the largest multinational clients on numerous cross-border transactions and multicountry tax planning opportunities, including inbound investments into the U.S. Mr. Terzian was the New England and Upstate New York international tax practice leader in KPMG’s Boston office and prior to that spent 12 years in KPMG’s New York-based international tax practice.Close
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