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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

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Conducted on Wednesday, January 11, 2023

Recorded event now available

or call 1-800-926-7926

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.

Description

The U.S. imposes taxes on foreign-sourced income of U.S. businesses and individuals, including certain income related to affiliated foreign companies. Tax reform added a new inclusion rule for controlled foreign corporation (CFC) income: the GILTI rule. Tax professionals must understand the nuances of the GILTI rules and reporting challenges.

With TCJA's creation of the GILTI anti-deferral regime under IRC Section 951A, all tax professionals serving U.S. businesses operating abroad via CFCs must understand the implications of the GILTI rules and the challenges they pose with regard to reporting GILTI. Since the GILTI rules are recent, sweeping, complex, and are still evolving, reporting the GILTI of a U.S. business is a task beset by uncertainties. The panel will provide tax professionals with guidance on how to navigate GILTI reporting issues involving Forms 5471, 8992, 8993, and 1118.

Listen as our panel provides tax professionals with guidance on the challenges of the GILTI rules. The panel will discuss calculating GILTI and the Section 250 deduction, particularly for individual taxpayers; reporting compliance; and navigating Forms 5471, 8992, 8993, and 1118. The panel will also offer tax planning tips to minimize the tax liability of taxpayers with CFC interests.

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Outline

  1. Determining if a U.S. business is subject to the GILTI rules
  2. Steps in determining a U.S. business' GILTI
  3. Reporting GILTI on:
    1. Form 5471
    2. Form 8992
    3. Form 8993
    4. 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

Dana, Michael
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

Horton, Melody
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

Fincher, Heather
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

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