Taxation of Foreign Branches Under Current Tax Law: Qualified Business Units, Foreign Tax Credits, Anti-Hybrid Rules
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax counsel and advisers with an in-depth analysis of the tax treatment of foreign branches of U.S.-based companies under current tax law. The panel will discuss what constitutes a foreign branch, reporting obligations, foreign tax credits, recent 267A anti-hybrid regulations, and other critical considerations for tax professionals.
- U.S. tax treatment of foreign branches
- Reporting requirements and ensuring compliance
- Comparison with foreign subsidiaries
- 267A anti-hybrid rules
- Foreign tax credits
- Best practices and planning strategies
The panel will review these and other critical issues:
- What constitutes a foreign branch?
- What are the applicable rules and available planning?
- Who is required to file Form 8858 and Schedule M?
- What is a branch mismatch payment under Section 267A?
- What are the differences between a foreign subsidiary and a foreign branch?
- How to obtain the foreign tax credit
Brian D. Dill, JD, LLM
Principal, Tax Services
Mr. Dill is Partner in charge of international tax. With over 20 years of experience he has extensive experience in... | Read More
Mr. Dill is Partner in charge of international tax. With over 20 years of experience he has extensive experience in forming and leading multi-jurisdictional teams from various disciplines on projects involving complex global tax issues, which have included global M&A, tax structuring, transfer pricing, withholding taxes/FATCA, VAT, tax attribute preservation and utilization, boycott operations, and foreign currency.Close
David J. Warner
Tax Attorney, Shareholder & Managing Principal
Holtz, Slavett & Drabkin
Mr. Warner is a Tax Attorney and the Managing Attorney of the Orange County Office of Holtz, Slavett &... | Read More
Mr. Warner is a Tax Attorney and the Managing Attorney of the Orange County Office of Holtz, Slavett & Drabkin. He has over 10 years of experience practicing in all aspects of tax controversy including tax audits, collection defense, and litigation in the U.S. Tax Court, U.S. District Court, and the Court of Federal Claims. He represents taxpayers in cases involving income tax, estate tax, gift tax, employment tax, collection issues, innocent spouse, penalties, and bankruptcy tax issues. He also represents taxpayers before the California Franchise Tax Board (FTB), Department of Fee and Tax Administration (CDTFA, formerly State Board of Equalization (BOE)), and Employment Development Department (EDD). He has particular expertise in tax matters involving individuals and small businesses, the examination of partnerships and S corporations, and offshore tax compliance issues, including the Report of Foreign Bank and Financial Accounts (FBAR), civil fraud, and offshore information return penalties.Close