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


Conducted on Wednesday, December 18, 2013

Recorded event now available

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Program Materials

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.

Description

Subpart F of the Internal Revenue Code, dealing with taxability of income generated by controlled foreign corporations (CFCs), presents many challenging issues for advisors and taxpayers. IRS scrutiny of foreign business relationships and Subpart F compliance for potential tax avoidance remains intense.

Calculating a pro-rata share of CFC income is often difficult depending on a particular taxpayer situation, to say nothing of which foreign tax rates apply. Those problems are only the beginning. How should Subpart F income be reported on Form 5741? How do voting agreements affect CFC determinations?

Subpart F-related issues likely to be brought up in a federal audit frequently shift based on IRS priorities. Tax advisors should revisit this important area of the Code and related IRS guidance and rulings to stay current and prepared for ongoing tax compliance and audit complexities.

Listen as our authoritative panel of tax advisors explores Subpart F in the context of the practical problems that taxpayers currently face.

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Outline

  1. Determination and tax treatment of a controlled foreign corporation
    1. Repatriation events
    2. CFC classification
    3. Attribution rules
  2. Selected types of Subpart F income
    1. Royalties
    2. Rents
    3. Gains on property sales
  3. Compliance and reporting issues
    1. FBCSI
  4. Potential IRS audit red flags

Benefits

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.

Faculty

Melinda Fellner Bramwit
Melinda Fellner Bramwit

Member
Norris McLaughlin & Marcus

Ms. Bramwit's practice emphasizes federal, state and international tax planning and transactions, particularly...  |  Read More

James K. Sams
James K. Sams
Principal
KPMG

Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical...  |  Read More

Vinay Navani
Vinay Navani

Shareholder
Wilkin & Guttenplan

He works primarily with high-tech, software and other closely held businesses on U.S. taxation of international...  |  Read More

Caren S. Shein
Caren S. Shein
Managing Director
KPMG

Ms. Shein works in the International Corporate Services group of KPMG's Washington National Tax office. She...  |  Read More

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