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

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

Conducted on Wednesday, February 24, 2021

Recorded event now available

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Course Materials

This CLE/CPE course 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.


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 income types 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 that 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 who own stock in certain foreign corporations by limiting the inquiries they must make to determine 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.



  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


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


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

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

Hatch, Kris
Kris Hatch

Fenwick & West

Mr. Hatch concentrates his practice on a broad variety of domestic and international tax matters.

 |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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