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
This CLE/CPE course will guide 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.
Outline
- Prior treatment of U.S. persons owning foreign corporations
- Recent IRS guidance and critical takeaways
- U.S. tax challenges under Subpart F
- U.S. tax challenges under GILTI
- 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

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 for nearly 3... | Read More
Mr. Acharya provides tax and accounting services, specializing in international tax and business issues for nearly 3 decades. He advises his clients on cross border tax matters, providing services to multinational clients engaged in US inbound or outbound activities. His services include planning, structuring, consulting, compliance and transfer pricing issues. He has worked extensively in the area of IRS overseas voluntary disclosure initiatives and helped clients comply with international tax requirements. He has a wealth of experience in cross border tax planning and compliance issues related to outbound and inbound US businesses as well as non-resident and expatriate individuals.
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Rolando Garcia, JD, CPA
Principal
Friedman
Mr. Garcia is a principal at Friedman where he leverages more than twenty years of experience to deliver clients tax... | Read More
Mr. Garcia is a principal at Friedman where he leverages more than twenty years of experience to deliver clients tax services that moves them closer to their goals. He represents individuals, closely held businesses, trusts, family offices, and international interests in virtually all industries. Mr. Garcia counsel clients concerning federal state and local, domestic U.S. and foreign tax regimes, tax planning and compliance, and special situations.
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Kris Hatch
Attorney
Fenwick & West
Mr. Hatch concentrates his practice on a broad variety of domestic and international tax matters.
| Read MoreMr. Hatch concentrates his practice on a broad variety of domestic and international tax matters.
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