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U.S. Foreign Tax Reporting for Individuals: International Repatriation and Inclusion Provisions

Section 962 Election, GILTI Inclusions, Intangible and Passive Income Treatment

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, May 14, 2020

Recorded event now available

or call 1-800-926-7926

This course will provide tax advisers and compliance professionals with a practical guide to the impact of the 2017 tax reform on U.S taxpayers with foreign income and tax reporting obligations. The panel will examine the significant changes the law imposes on calculating and reporting taxable foreign-source income and will discuss the latest regulatory guidance issued by the Service.

Description

The tax consequences of an individual U.S. person holding foreign assets have changed substantially. Recent tax reform and updated regulations contain numerous provisions that have had a dramatic impact on U.S. individuals engaged in international business activities.

New attribution rules have created more CFCs, while the ability to defer foreign earnings has been severely diminished. The GILTI regime subjects certain income to tax at ordinary rates while individuals remain subject to Subpart F rules. Recent regulations issued to clarify areas of uncertainty have created new questions and planning opportunities.

These opportunities include holding structure choices, making the Section 962 election, and taking advantage of treaty provisions and tax credits. Tax advisers serving individual and small business clients with foreign-source income must avoid costly tax consequences by becoming proficient in the latest concepts.

Listen as our experienced panel provides a critical look at the cross-border implications of the latest tax reforms, including steps to take to minimize an individual taxpayer's effective global tax rate.

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Outline

  1. Cross-border provisions and definitions
  2. Ownership structures: considerations for residents and NRAs
  3. CFCs and GILTI
  4. Subpart F income
  5. Section 965, repatriation and proposed double-taxation relief
  6. Section 962, individual election to be taxed at corporate rates
  7. Takeaways and strategies

Benefits

The panel will discuss these and other relevant topics:

  • How the definitions of U.S. shareholders subject to tax on previously deferred foreign-source income have changed
  • Critical income inclusion and Section 965 repatriation provisions
  • Treatment of foreign passive and intangible income under the new rules
  • GILTI and Subpart F income

Faculty

Grinberg, Ora
Ora Grinberg
Attorney
Fenwick & West

Ms. Grinberg focuses her practice on U.S. corporate and international taxation. She represents clients in tax planning...  |  Read More

McCormick, Patrick
Patrick J. McCormick, J.D., LL.M.
Partner
Culhane Meadows Haughian & Walsh

Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting...  |  Read More

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