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
A live 110-minute CPE webinar with interactive 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

Eric Tohni
Director, Global Tax Reporting
Expedia Group
Mr. Tohni's responsibilities include compliance and provision reporting of Expedia Group's international... | Read More
Mr. Tohni's responsibilities include compliance and provision reporting of Expedia Group's international operations, such as US tax return compliance, foreign tax credits, foreign-derived intangible income ("FDII"), deemed income inclusions, repatriations, indefinite reinvestment, and deferred tax assets/liabilities related to these items.
Closeto be announced.
Early Discount (through 06/23/23)
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event.
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NASBA details.
Cannot Attend July 20?
Early Discount (through 06/23/23)
CPE credit is not available on downloads.
CPE On-Demand