Subpart F Expansion After Tax Reform: Increased Tax Liability and Reporting Obligations
New Controlled Foreign Corporation and U.S. Shareholder Definitions, GILTI, Transition Tax
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical overview of the significant changes the 2017 tax reform law made to Subpart F tax treatment of controlled foreign corporations (CFCs). The panel will detail in plain language the specific areas where the law expanded Subpart F, including for example the new "downward" attribution rules, and discuss how these changes will create new foreign information reporting requirements on Form 5471.
Outline
- Existing Subpart F framework
- Identify the definition of a CFC
- "U.S. shareholder"
- Income inclusions and rates
- Allowable exclusions
- Expansion of Subpart F in the new tax reform law
- Expanded definition of a CFC and U.S. shareholder
- The additional income included in the calculation base
- Disparate treatment between corporate shareholders and individual shareholders of CFCs
- Downward attribution rules
- Section 951A GILTI current tax
- Overview
- Key updates from regulations
- Proposed high tax exclusion
- Interaction with Section 956
- Identifying new Form 5471 reporting obligations
Benefits
The panel will discuss these and other important topics:
- How the 2017 tax law's expansion of the definitions of CFCs and U.S. shareholders will create new tax and reporting obligations for U.S. taxpayers previously exempt from filing duties
- Constructive ownership tests in CFCs after the new downward attribution rules
- How the Subpart F changes run counter to the tax law's general aim to convert to more territorial taxation of U.S. taxpayers as opposed to global-based
- Treatment of earnings invested in U.S. property
Faculty
Pamela A. Fuller, JD, LLM
Of Counsel
Royse Law Firm
Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity... | Read More
Ms. Fuller advises a wide range of clients--including private and public companies, joint ventures, private equity funds, individuals, C-Suite executives, “start-ups,” and government entities--on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. As a seasoned practitioner and tax technician, Ms. Fuller is accustomed to handling nuanced matters involving highly technical questions of law, policy, and procedure at the federal, state, local, and international levels. She provides sophisticated tax planning services across most industry sectors, including software & emerging digital technologies, financial services, real estate development, healthcare, pharmaceutical, construction & engineering, infrastructure, oil & energy, and retail.
Ms. Fuller also has nearly two decades of experience resolving U.S. federal, state, and foreign tax controversies, as well as asserted tax penalties.
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James K. Sams
Principal, International Corporate Tax
KPMG
Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical... | Read More
Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical assistance and tax consulting to clients on inbound and outbound tax issues. He previously served in several roles with the IRS Office of Chief Counsel.
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