Subpart F Income Taxation: Latest Compliance Developments
Mastering Income Calculation, Tax Rates, Audit Preparation and Other Complexities
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisors with an analysis of the relevant terms of Subpart F and guidance in the context of practical situations frequently faced in U.S. federal income tax compliance, reporting and audits.
Determination and tax treatment of a controlled foreign corporation
- Repatriation events
- CFC classification
- Attribution rules
Selected types of Subpart F income
- Gains on property sales
Compliance and reporting issues
- Potential IRS audit red flags
The panel will address these and other crucial topics:
- The key material terms of Subpart F and related IRS guidance, including the foreign branch rules.
- Income and tax calculations with CFCs, given various exclusions.
- Reporting issues that U.S. taxpayers routinely face.
- Subpart F matters that should be covered in preparing for IRS audit.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Melinda Fellner Bramwit
Norris McLaughlin & Marcus
Ms. Bramwit's practice emphasizes federal, state and international tax planning and transactions, particularly in... | Read More
Ms. Bramwit's practice emphasizes federal, state and international tax planning and transactions, particularly in regard to corporate acquisitions. She routinely represents clients in federal and state tax controversies and on IRS offshore voluntary compliance participation.Close
James K. Sams
Principal, International Corporate Tax
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.Close
Wilkin & Guttenplan
He works primarily with high-tech, software and other closely held businesses on U.S. taxation of international... | Read More
He works primarily with high-tech, software and other closely held businesses on U.S. taxation of international business, income tax planning and compliance matters. He previously worked on tax research services for the AICPA.Close
Caren S. Shein
Ms. Shein works in the International Corporate Services group of KPMG's Washington National Tax office. She... | Read More
Ms. Shein works in the International Corporate Services group of KPMG's Washington National Tax office. She advises clients on outbound and inbound international tax planning and compliance issues, including foreign tax credit, subpart F, expense allocation, and permanent establishment.Close