U.S. GILTI Anti-Deferral Rules and Tax Compliance: Reporting Issues, Navigating Forms 5471, 8992, 8993, and 1118
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax professionals with an in-depth discussion of the challenges posed to U.S. businesses that must report their global intangible low-taxed income (GILTI). The panel will discuss how GILTI is calculated and key tax GILTI reporting issues involving IRS Forms 5471, 8992, 8993, and 1118.
Outline
- Determining if a U.S. business is subject to the GILTI rules
- Steps in determining a U.S. business' GILTI
- Reporting GILTI on:
- Form 5471
- Form 8992
- Form 8993
- Form 1118
Benefits
The panel will review these and other key issues:
- Determining whether a taxpayer is subject to GILTI tax under Section 951A
- Calculating GILTI on CFC income
- Navigating tax reporting issues on Forms 5471, 8992, 8993, and 1118
- Recognizing the reporting requirements and possible credits or deductions
- Impact of final Section 250 regulations
- Strategies to defer or minimize the GILTI tax
Faculty
Michael Dana
Partner
Husch Blackwell
Mr. Dana provides tax and corporate law advice to businesses at all phases of operation, from initial business... | Read More
Mr. Dana provides tax and corporate law advice to businesses at all phases of operation, from initial business formation to disposition and all points in between. He advises clients across virtually all areas of operation regarding U.S. federal income tax issues. Mr. Dana has represented U.S.-based, foreign-based, and multinational enterprises, providing advice in connection with acquisitions, distribution structures, and internal reorganizations, including complex crossborder transactions; U.S. Subpart F income and GILTI planning and analysis; foreign tax credit planning and analysis; tax treaty analysis, and other matters related to outbound and inbound U.S. tax planning. His representations have included business structures, operations, and investments by US clients in, or by non-US clients from, Europe, Canada, Latin America and a number of other jurisdictions outside of the U.S. He also works with closely held businesses and their owners to develop and implement tax strategies that protect and enhance corporate value.
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Melody C. Horton, CPA
Founder
Arc Advisors
Ms. Horton has spent her career in public accounting, specializing in working with clients with international... | Read More
Ms. Horton has spent her career in public accounting, specializing in working with clients with international activities. She provides comprehensive planning and compliance services to clients with multi-state and multinational operations across a variety of industries. Ms. Horton primarily works with clients that have international operations in the manufacturing, distribution, technology, and services industries. She assists many international companies making inbound investment in the US with tax structuring and economic incentives. Ms. Horton also works with international companies to create efficient global tax strategies, maximizing their FDII benefits and minimizing the GILTI and BEAT impact. She has significant experience with income tax provisions and other ASC 740 reporting matters, international reporting requirements, foreign tax credit planning, repatriation of foreign profits, treaty analysis and voluntary disclosure filings.
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Heather K.P. Fincher
Attorney
Kostelanetz
Ms. Fincher advises multinational businesses and high-net-worth individuals on US federal income tax matters, with a... | Read More
Ms. Fincher advises multinational businesses and high-net-worth individuals on US federal income tax matters, with a particular focus on international tax planning and controversies. She counsels both US- and foreign-owned businesses and individuals regarding the US tax consequences of cross-border investments, cryptocurrency issues, mergers and acquisitions, joint ventures and restructurings. Ms. Fincher also regularly advises clients on special issues arising in international tax controversies.
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