Domesticating Individually-Owned Controlled Foreign Corporations Post-Tax Reform
Restructuring CFCs for U.S. Taxpayers, Mitigating Tax Liability, Section 962 Election, Transition Tax
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This webinar will provide guidance to tax professionals and advisers on the legal challenges and available planning techniques for domesticating individually-owned controlled foreign corporations (CFCs) post-tax reform. The panel will discuss rules governing U.S. persons with non-U.S. businesses and investments, the impact of tax reform on non-corporate U.S. shareholders of foreign corporations, methods in mitigating increased tax liability, Section 962 elections, and the application of Section 965 for purposes of domestication of a foreign corporation.
- Tax reform changes to CFC rules
- Recent IRS regulations and guidance for individual and pass-through shareholders
- Domestication and restructuring strategies of CFCs for U.S. taxpayers
- Best practices to minimize unforeseen tax liability
The panel will discuss these and other key issues:
- How does tax reform impact rules governing U.S. persons with non-U.S. businesses and investments?
- What factors must be considered by non-corporate U.S. shareholders of foreign corporations?
- What methods are available for domesticating or restructuring CFCs for U.S. taxpayers?
- How can Section 962 elections ensure tax savings?
- Application of the transition tax and GILTI for purposes of domesticating of a foreign corporation
Ms. Brunoro-Borokhov’s practice is focused on assisting businesses and individuals with business and tax related... | Read More
Ms. Brunoro-Borokhov’s practice is focused on assisting businesses and individuals with business and tax related matters, where her diverse background, strong analytical and communication skills come into play. She has vast experience assisting domestic clients in all sorts of tax controversy matters and tax planning for individuals and families. Ms. Brunoro-Borokhov also performs a role of a general counsel, where she assists clients with the most various and complex business and corporate issues. Paula also handles international business and tax matters, such as tax planning for multinational families and business, international tax audits, offshore voluntary disclosures, cross border transactions, transfer pricing, tax treaties and foreign tax credit. She also provides guidance and representation to clients in Brazil, Mexico and other Latin American countries and assists American clients with assets or business relations in those countries.Close
William R. Skinner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.Close