Tax Considerations of Repatriation: Previously Taxed E&P, Non-PTEP, Return of Capital, Multi-Tiered Distributions
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This webinar will cover repatriation issues for multinational taxpayers. Our panel of foreign tax experts will examine distributions of E&P from PTEP, non-PTEP, and the return of basis and explain the tax considerations and benefits available for each distribution type.
- Taxation regimes
- Subpart F
- Section 965 transition tax
- PTEP and ordering rules
- Non-PTEP and 245A DRD
- Return of basis
- Foreign currency gains and losses
- Foreign withholding and tax credits
The panel will cover these and other critical issues:
- Identifying distributions for ordering rules
- Analyzing distributions of PTEP and non-PTEP for tax consequences
- Calculating gain or loss on returns of capital
- Determining foreign currency gains and losses
- When non-PTEP distributions may be eligible for a 245A dividends received deduction
Mark C. Gasbarra, CPA
National Managing Director
Forte International Tax
Mr. Gasbarra has more than thirty-five years of international tax experience serving a wide array of companies across... | Read More
Mr. Gasbarra has more than thirty-five years of international tax experience serving a wide array of companies across many industries. He serves major multinational corporations and CPA firms throughout the U.S., as well as privately held businesses with international operations. He advises on a wide range of international tax matters with deep expertise in outbound issues including repatriation, foreign tax credit utilization, export incentives, including the IC-DISC, and the domestic production activities deduction. Prior to founding Forte in 2004, he was the lead partner in EY's Chicago-based International Tax Services department, and prior to that position, he was an International Tax Service Partner at PwC.Close
Patrick J. McCormick, J.D., LL.M.
Culhane Meadows Haughian & Walsh
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close
Early Discount (through 05/14/21)
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.