Subpart F Rules on Taxation of Controlled Foreign Corporations
Navigating the Complexities in Tax Planning for Multinational Companies
Recording of a 90-minute CPE/CLE webinar with Q&A
This CLE course will prepare counsel and advisors to multi-national companies to meet the requirements of the current Subpart F rules governing the taxation of controlled foreign corporations. The panel will review recent enforcement developments and discuss key tax planning strategies.
- Determination of a controlled foreign corporation (CFC)
- What is a CFC?
- Control tests
- Attribution rules
- Tax treatment of CFC income
- In general
- Subpart F income
- Exceptions and limitations
- Special issues and legal developments
- Investments in U.S. property
- Treatment of previously taxed income
- Subpart F Income partnership blocker transactions
- Legislative reform
The panel will review these and other key questions:
- What is the effect of voting agreements on CFC determination?
- How can CFCs take advantage of recent guidelines allowing CFCs to improve liquidity without increasing the amount of U.S. property under section 956?
- What tax reform initiatives and enforcement trends can multinational companies expect to see in the near future?
Daniel L. Gottfried
His practice encompasses domestic and international business transactions, as well as federal, state, and international... | Read More
His practice encompasses domestic and international business transactions, as well as federal, state, and international tax planning, including corporate mergers, acquisitions and dispositions, joint ventures, partnerships and S corporations. He is regularly called on to assist business clients with cross-border expansion, including expansion into the U.S. and abroad.Close
Holland & Knight
He practices focuses on domestic and international taxation. He has experience in a broad range of transactions... | Read More
He practices focuses on domestic and international taxation. He has experience in a broad range of transactions involving U.S. taxpayers doing business overseas, foreign taxpayers doing business in the U.S., tax planning for mergers and acquisitions, restructurings and joint ventures, and federal, state and local tax issues with corporate reorganizations, partnerships, and S corporations.Close
Michael J. Miller
Roberts & Holland
Mr. Miller has provided U.S. tax advice to domestic and international clients for more than 15 years. Working with... | Read More
Mr. Miller has provided U.S. tax advice to domestic and international clients for more than 15 years. Working with foreign clients, he has structured inbound U.S. investments and operations to avoid creation of U.S. permanent establishment and developed structures to take advantage of U.S. income tax treaties, the withholding tax exemption for portfolio interest, and other rules for minimizing U.S. tax. He is an editor of the International column for the Journal of Taxation and is currently Chair of the Business Entities Committee of the New York City Bar and Chair-Elect of the U.S. Activities of Foreign Taxpayers Committee of the American Bar Association Tax Section.Close