Taxation of Foreign Source Income: GILTI HTE Regulations, Subpart F, Sec. 245A DRD, Sale of Interest, Attribution
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax professionals with guidance on final and proposed regulations governing foreign source income taxation. The panel will present an in-depth analysis of changes in the application of Subpart F as a result of the TCJA, global intangible low-taxed income (GILTI), the territorial dividends received deduction (DRD), and the Code Section 962 election.
Outline
- Taxation of foreign source income: An overview
- Code 245A and foreign-source dividends received deduction
- Final regulation
- Sales and other transfers of stock in foreign corporations
- Subpart F: CFC ownership attribution rules
- GILTI and foreign-derived intangible income
Benefits
The panel will review these and other relevant issues:
- The changes to the attribution rules
- Understanding U.S. reporting requirements for foreign income as affected by the TCJA
- Tax implications of sales or transfers of shares of CFCs by U.S. individual and corporate shareholders
- Guidance for determining when electing the GILTI HTE may be beneficial
- Best practices and planning techniques for tax professionals regarding the taxation of foreign income
Faculty
Galia Antebi
Managing Member
Ruchelman
Ms. Antebi focuses her practice on the international and domestic tax aspects of business structuring for worldwide... | Read More
Ms. Antebi focuses her practice on the international and domestic tax aspects of business structuring for worldwide investments. She also advises individuals on inbound and outbound investments, as well as on pre-immigration, expatriation and estate planning, including trust issues and gift tax planning. She is co-chair of the F.A.T.C.A. practice and advises large N.F.F.E.’s and F.F.I.’s on F.A.T.C.A. matters. Previously, she worked as an attorney in the tax department of a major international law firm in New York City and at a leading, internationally-recognized Israeli law firm, where her practice focused on a variety of corporate issues as well as trust issues.
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Andreas A. Apostolides
Attorney
Ruchelman
Mr. Apostolides offers thoughtful and thorough advice to his clients and helps them find significant efficiencies in... | Read More
Mr. Apostolides offers thoughtful and thorough advice to his clients and helps them find significant efficiencies in structuring cross-border transactions and reorganizations.
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Stanley C. Ruchelman
Chairman
Ruchelman
Mr. Ruchelman concentrates his practice in the area of tax planning for transactional business operations, with... | Read More
Mr. Ruchelman concentrates his practice in the area of tax planning for transactional business operations, with emphasis on intercompany transactions. He represents companies in matters involving the I.R.S. and counsels corporate clients on transfer pricing issues and worldwide reorganizations. He advises foreign private clients on structuring investments in the United States. He authors and speaks on international taxation. Previously, he was an international tax partner at a major international accounting firms and was a senior attorney in the Legislation & Regulations Division of the Office of Chief Counsel, Internal Revenue Service, where he participated in the negotiation of income tax treaties and the development of legislative and regulatory policy affecting international business.
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Neha Rastogi
Attorney
Ruchelman
Ms. Rastogi is known for her thorough and professional approach to international tax matters. At Ruchelman, she... | Read More
Ms. Rastogi is known for her thorough and professional approach to international tax matters. At Ruchelman, she regularly advises domestic and foreign clients on tax-efficient structuring. Her cross-border practice is informed by her diverse experience in the tax environment. Before joining the firm, she qualified as an advocate and a member of the Institute of Chartered Accountants of India and worked at a leading tax law firm based in New Delhi. There she focused on planning and controversy matters, advising on the corporate income tax implications of activities in India as well as personal income tax and related compliance obligations.
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