Tax Reform and U.S. Foreign Reporting for Individuals: Cross-Border Repatriation and Inclusion Provisions
Section 962 Election, GILTI Inclusions, Intangible and Passive Income Treatment
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide tax advisers and compliance professionals with a practical guide to the impact of the 2017 tax reform on U.S taxpayers with foreign income and tax reporting obligations. The panel will examine the significant changes the law imposes on calculating and reporting taxable foreign-source income and will discuss the latest regulatory guidance issued by the Service.
- Cross-border provisions and definitions
- Ownership structures: considerations for residents and NRAs
- CFCs and GILTI
- Subpart F income
- Section 965, repatriation and proposed double-taxation relief
- Section 962, individual election to be taxed at corporate rates
- Takeaways and strategies
The panel will discuss these and other relevant topics:
- How the definitions of U.S. shareholders subject to tax on previously deferred foreign-source income have changed
- Critical income inclusion and Section 965 repatriation provisions
- Treatment of foreign passive and intangible income under the new rules
- GILTI and Subpart F income
Fenwick & West
Ms. Grinberg focuses her practice on U.S. corporate and international taxation. She represents clients in tax planning... | Read More
Ms. Grinberg focuses her practice on U.S. corporate and international taxation. She represents clients in tax planning and tax controversy matters, with emphasis on international tax planning, cross-border and domestic mergers and acquisitions and restructuring. Ms. Grinberg's clients come from a diverse set of industries and geographic jurisdictions (including both domestic and foreign entities) and range in size from startups to large Fortune 500 companies.Close
Patrick J. McCormick, J.D., LL.M.
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
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