Taxation of U.S. Persons Owning Foreign Corporations: Strategies for Subpart F and GILTI Inclusions

Recording of a 90-minute premium CLE/CPE webinar with Q&A


Conducted on Tuesday, January 21, 2020

Recorded event now available

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Program Materials

This CLE/CPE webinar will provide guidance to tax counsel and advisers on the implications and potential opportunities for U.S. persons owning foreign corporations under recent IRS guidance and current tax law. The panel will discuss key tax provisions and regulations causing compliance issues for U.S. taxpayers, Subpart F tax treatment of controlled foreign corporations (CFCs), global intangible low-tax income (GILTI), significant tax modifications for U.S. persons owning stock of foreign corporations through domestic partnerships, and best practices for ensuring accurate reporting and compliance.

Description

The GILTI provisions and expanded Subpart F rules have a significant impact on U.S. owners of foreign corporations. Tax professionals must recognize implications and potential opportunities for U.S. persons owning foreign corporations under recent IRS guidance and current tax law.

The Subpart F rules require "U.S. shareholders" of CFCs to treat certain types of income as taxable in the current year. Section 250 adds a layer of current income inclusion for CFC shareholders on global "intangible income" but also provides a deduction which reduces the effective tax rate on the included income.

The repeal of Code Sec. 958(b)(4) forces certain taxpayers to include in gross income amounts under Subpart F and GILTI attributable to foreign corporations that are CFCs, even though they may have limited access to critical items to determine whether such foreign corporations are CFCs and their inclusion amounts.

Rev Proc 2019-40 provides relief to certain U.S. persons that own stock in certain foreign corporations by limiting the inquiries they must make in determining whether certain foreign corporations are CFCs. It also offers particular unrelated minority U.S. shareholders the ability to rely on limited information to calculate subpart F and GILTI inclusions in the absence of detailed financial statement information.

Listen as our authoritative panel of international tax practitioners reviews the Subpart F rules and GILTI provisions and provides a practical guide to determining CFC ownership and reporting obligations for U.S. persons owning foreign corporations.

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Outline

  1. Prior treatment of U.S. persons owning foreign corporations
  2. Recent IRS guidance and critical takeaways
  3. U.S. tax challenges under Subpart F
  4. U.S. tax challenges under GILTI
  5. Best practices for ensuring accurate reporting and compliance

Benefits

The panel will review these and other key issues:

  • Key tax compliance challenges for U.S. persons owning foreign corporations
  • Recent IRS regulations and guidance for U.S. taxpayers
  • Expanded definition of a CFC and U.S. shareholder
  • Expansion of Subpart F and key challenges under new tax law
  • Challenges under Section 951A GILTI rules for U.S. taxpayers
  • Tax planning and methods to ensure accurate reporting and compliance

Faculty

Acharya, Pallav
Pallav Acharya, CPA, FCA, CGMA

Founder and Owner
CPA Global Tax & Accounting

Mr. Acharya provides tax and accounting services, specializing in international tax and business issues. He advises his...  |  Read More

Garcia, Rolando
Rolando Garcia, JD, CPA

Shareholder
Doeren Mayhew

Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for...  |  Read More

Knobler, Michael
Michael Knobler

Attorney
Fenwick & West

Mr. Knobler focuses his practice on U.S. international and domestic tax planning, mergers and acquisitions, and...  |  Read More

Other Formats
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Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

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$347

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CPE Not Available

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