Tax Reform and U.S. Foreign Reporting for Individuals: New Cross-Border Repatriation and Inclusion Provisions
Navigating Participation Exemption System, GILTI Inclusions, Intangible and Passive Income Treatment
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 Tax Cuts and Jobs Act 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 regulatory guidance issued by the Service during 2018.
- New cross-border provisions and definitions in 2017 tax overhaul bill
- U.S. shareholders subject to new foreign provisions
- The territorial regime for foreign-sourced qualified dividends
- Inclusion in 2017 income of pro rata share of accumulated deferred foreign income of corporation
- Participation exemption system
- GILTI and inclusion of passive foreign income
- Treatment of foreign intangibles
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 under the new law
- Critical income inclusion and repatriation provisions effective in 2018
- Treatment of foreign passive and intangible income under the new rules
- GILTI and application of Subpart F
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.
Drucker & Scaccetti
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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