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Form 8832 Check-the-Box Entity Elections Under Section 7701: Selecting Entities for Foreig...
July 18, 2022 CPE, EA Live Webinar
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This course will provide tax advisers with practical guidance on the advantages and pitfalls of utilizing the check-the-box entity selection for U.S. individuals with offshore business activities. The panel will discuss the various tax effects of specific elections, outline the tax timing and treatm... Read More

Basics of Foreign Tax Reporting: Identifying Filing Requirements
Inbound vs. Outbound Reporting Duties, Intersection Between Information Reporting and Inco...
August 23, 2022 CPE, EA Live Webinar
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This course will provide tax advisers and professionals with a sound foundation for identifying foreign tax and asset information requirements for taxpayers. The webinar will identify reporting requirements, differentiate between inbound and outbound filing duties, and detail the intersection betwee... Read More

Form 8621 PFIC Reporting: Passive Foreign Investment Company Rules
Proposed and Final Regs, Subpart F Expansion, Dealing With Dual CFC/PFIC Status, QEF Elect...
June 14, 2022 CPE, EA CPE On-Demand, Download
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This course will furnish tax advisers with a thorough and practical guide to reporting investments in a passive foreign investment company (PFIC) on IRS Form 8621. The panel will identify those investments that require PFIC reporting, outline the various elections available to taxpayers holding inte... Read More

International Tax Disputes: FBAR Violations, Penalty Stacking, Form 3520, Accidental Ameri...
Lessons Learned From Current and Notable Cases
May 24, 2022 CPE, EA Download
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This webinar will analyze the most recent and relevant court cases affecting international taxpayers. Our panel of foreign tax veterans will detail the status of recent and notable cases and offer insights for handling common international tax and compliance problems. Read More

Foreign Tax Credits for Individuals: Form 1116 Changes, Final and Proposed Regulations
GILTI High-Tax Exception, Limitations and Calculations, Income Baskets, Carryovers
May 19, 2022 CPE, EA CPE On-Demand, Download
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This course will provide a practical guide to completing Form 1116 to claim foreign tax credits (FTCs) in the aftermath of recently released regulations and considering the addition of the new Schedules K-2 and K3 for pass-through entities. The panel will outline which foreign taxes are eligible for... Read More

GILTI Calculations for Individual CFC Shareholders: Section 951A Tax on Foreign Intangible...
Changes to Subpart F Controlled Foreign Corporation Treatment, Recognizing QBAI, and More
March 22, 2022 CPE, EA CPE On-Demand, Download
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This course will provide tax advisers with a practical guide to the tax reform bill's global intangible low-taxed income (GILTI) provisions. The panel will detail the tax calculations and reporting requirements for taxpayers with GILTI inclusions and describe planning opportunities to minimize the t... Read More

IRC 962 Election for Corporate Tax Rate on Subpart F Income
Avoiding GILTI Complexities, Claiming Indirect Deemed Paid Foreign Tax Credits, and NOL Ca...
March 1, 2022 CPE, EA CPE On-Demand, Download
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This course will guide tax advisers in making a Section 962 election for an individual, trust, or estate to be taxed at corporate rates on foreign-sourced income under Section 951(a) and global intangible low-taxed income (GILTI) treated in the "same manner" as Subpart F inclusions. The panel will s... Read More

Form 8858 Reporting of U.S. Owned Foreign Disregarded Entities: Ownership and Correct Fili...
Information Return Requirements for Check-the-Box Structures Including Indirect and Constr...
January 11, 2022 CPE, EA CPE On-Demand, Download
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This course will guide tax advisers to the U.S. reporting requirements for ownership of foreign disregarded entities (FDEs) on IRS Form 8858. The panel will offer section-by-section detail on completing Form 8858, discuss the interrelation between Form 8858 and other required international informati... Read More

GILTI High-Tax Exclusion Final Regulations: Tested Units, Controlled CFC Groups, and Retro...
November 16, 2021 CPE, EA CPE On-Demand, Download
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This course will provide CFC shareholders and tax professionals with a comprehensive understanding of the final global intangible low-taxed income (GILTI) High-Foreign-Tax Exclusion Regulations (T.D. 9902). Our panel of international tax experts will explain how the final regulations change the orig... Read More

Foreign Branches, QBUs, and Disregarded Entities: Foreign Tax Credits, Anti-Hybrid Rules,...
September 21, 2021 CPE, EA CPE On-Demand, Download
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This course will explain foreign branches' tax considerations, including what constitutes a foreign branch and its U.S. reporting obligations, calculating foreign branch income and the related foreign tax credit, and the recent 267A anti-hybrid regulations. Read More

Section 965 Payment Acceleration Events: Avoiding Triggers, Curable Events
August 24, 2021 CPE, EA Download
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This course will point out specific actions that accelerate the deferred payment of tax on repatriated earnings under IRC Section 965. Our veteran panel of foreign tax experts will discuss which actions are curable, how to cure these, and identify ways to avoid activities triggering the acceleration... Read More

Calculating and Reporting Foreign E&P: Categorizing PTEP, Form 5471 Schedules H, P & R, Fo...
July 13, 2021 CPE, EA CPE On-Demand, Download
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This course will discuss the complications surrounding the determination of foreign earnings and profits (E&P) for controlled foreign corporations (CFCs). Our panel of foreign tax experts will discuss the complexities of the related calculations, including categorizing income, handling retroactive a... Read More

Tax Considerations of Repatriation: Previously Taxed E&P, Non-PTEP, Return of Capital, Mul...
June 8, 2021 CPE, EA Download
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This course will cover repatriation issues for multinational taxpayers. Our panel of foreign tax experts will examine distributions of E&P from PTEP, non-PTEP, and the return of basis and explain the tax considerations and benefits available for each distribution type. Read More

Form 8865: Reporting Foreign Partnership Interests
Determining Taxpayer Categories Based on Control or Ownership, Calculating Allocable Share...
June 1, 2021 CPE, EA Download
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This course will provide tax advisers and return preparers with a practical guide to completing Form 8865, Return of U.S. Persons with Respect to Certain Foreign Partnerships. The panel will discuss how to correctly identify the taxpayer category, determine the allocable share of foreign income, com... Read More

Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Incom...
February 23, 2021 CPE, EA CPE On-Demand, Download
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This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and nonresidential rentals, and properly reporting rental income and expenses with a... Read More

International Tax Issues for Athletes and Entertainers: Residency, Tax Treaty Provisions,...
August 20, 2020 CPE, EA Download
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This course will discuss ways to mitigate the tax burden for foreign athletes and entertainers. Our international taxation experts will discuss residency requirements along with structuring opportunities, tax treaty benefits, and withholding considerations for U.S. resident and nonresident performer... Read More

Section 267A New Final Anti-Hybrid Regulations
Hybrid Deduction Accounts, Foreign Hybrid Mismatch Rules, and Notional Interest Deductions
August 13, 2020 CPE, EA Download
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This course will cover the disallowance of deductions for certain hybrid transactions with related parties under Section 267A, including an analysis of the April 2020 finalized and proposed regulations. Read More

Sourcing U.S. and Foreign Income: Dividends, Service Income, Property Sales, Rents, and In...
July 8, 2020 CPE, EA Download
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This course will provide a comprehensive review of how income is sourced to the U.S. and other countries. Our authoritative panel will provide insights to help mitigate multi-country taxation and avoid improper classifications of income. They will explain the benefits available in particular income... Read More

Global Entity Structuring: U.S. Taxpayers Doing Business Abroad
U.S. or Foreign, Corporation or Pass-Through, FTCs, Treaty Provisions and Relief Under 962
June 11, 2020 CPE, EA Download
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This course will weigh the pros and cons of holding structure choices for foreign investments made by U.S. taxpayers. Our panel will explore the tax impact of entity choice as well as relief available for advisers working with taxpayers with global income. Read More

Form 8854 Exit Tax Calculations and Reporting and IRS Relief Procedures for Certain Former...
Determining Covered Expatriate Status, Navigating the Mark-to-Market Tax, and Expatriation...
February 20, 2020 CPE, EA Download
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This course will provide tax advisers and compliance professionals with a practical guide to the basic calculations and reporting requirements needed for U.S. taxpayers and exiting green card holders. The panel will discuss the rules of Section 877A, how to determine if you are a covered expatriate,... Read More

Outbound Foreign Income Tax Reporting Basics: Filing Requirements and Thresholds
Reconciling Income, Credits and Treaty Benefits, Foreign Entity Classification, GILTI
December 10, 2019 CPE, EA Download
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This course will provide tax advisers with a guide to the framework of reporting foreign income and its accompanying tax obligations. The panel will detail the tax treatment of various classes of income, describe the remaining framework of deferral opportunities, credits for foreign taxes paid, tax... Read More

Subpart F Expansion After Tax Reform: Increased Tax Liability and Reporting Obligations
New Controlled Foreign Corporation and U.S. Shareholder Definitions, GILTI, Transition Tax
December 3, 2019 CPE, EA Download
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This course will provide tax advisers with a practical overview of the significant changes the 2017 tax reform law made to Subpart F tax treatment of controlled foreign corporations (CFCs). The panel will detail in plain language the specific areas where the law expanded Subpart F, including for exa... Read More

New IRS Form 965 Line-by-Line: Reporting Section 965 Transition Tax Inclusions, Deductions...
Tying Forms 965 and 965-A to Required Schedules and 2017 Transition Tax Statement
November 12, 2019 CPE, EA Download
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This course will provide tax advisers with a practical guide to reporting the repatriation provisions of the transition tax on new Form 965. The webinar presumes the attendees already are versed in the provisions of Section 965 and will bypass the fundamentals of the statute to offer a line-by-line... Read More

Remedying Incorrect Section 965 Inclusions After Final Regulations
Determining How to Make Forward Adjustments to 965(h) Installment Amounts Absent IRS Guida...
August 21, 2019 CPE, EA Download
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This course will provide tax advisers with a practical guide to remedying late or incorrect deemed repatriation filings required under Section 965 in the absence of detailed guidance from the IRS. The panel will describe recent IRS guidance offering relief from estimated tax penalties for failure to... Read More

IRC 338(g) Elections for Buyers of Controlled Foreign Corporation Stock in Wake of Major C...
Section 1248(j) and 100% Dividends Received Deduction and Impact of GILTI Claiming Basis S...
February 28, 2019 CPE, EA Download
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This course will provide tax advisers to individuals with a practical guide to the tax implications of Section 338(g) election on the purchase of controlled foreign corporation (CFC) stock. The panel will discuss the mechanics of taking a basis adjustment under IRC 338(g) and describe how the 2017 t... Read More

New IRS Foreign Tax Credit Regulations: IRC 904 Limitation, Allocation/Apportionment Rules...
Additional Income Buckets, Carryover and Carryback Rules, GILTI Application
February 12, 2019 CPE, EA Download
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This course will provide tax advisers with a critical first look at new IRS proposed guidance on calculating foreign tax credit (FTC) limitations under Section 904. The panel will outline which additional "buckets" for foreign income grouping the new regulations create, discuss new rules regarding t... Read More

Foreign Entity Selection for U.S. Owners of Offshore Businesses: Avoiding Tax and Reportin...
Applying U.S. Law to Foreign Structures, Determining Whether Foreign Trust Qualifies for U...
January 17, 2019 CPE, EA Download
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This course will provide tax advisers to individuals owning controlling shares in foreign businesses with a practical guide to the tax and operational impacts of selecting the entity form for those foreign entities. The panelist will discuss the full range of short-term and long-term tax issues that... Read More

Completing Form 8833 Treaty-Based Return Position Disclosure: Claiming Income Tax Treaty B...
Identifying Treaty Provisions and Impacted Code Sections, Interrelated Filings, and Impact...
November 7, 2018 CPE, EA Download
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This course will provide tax advisers and compliance professionals with an in-depth and practical guide to completing IRS Form 8833 Treaty-Based Return Disclosure. The panel will detail the requirements of Section 6114 and describe how to identify scenarios where a tax treaty may allow a taxpayer to... Read More

New IRS Guidance for Foreign Deemed Repatriation Transition Tax Relief Under Section 965
Avoiding Late Payment Penalties and Transition Tax Acceleration, Correcting Underpayments,...
September 25, 2018 CPE, EA Download
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This course will provide tax advisers with an updated, practical guide to correcting errors and underpayments on the deemed repatriation provisions of Section 965. The panel will focus on recent IRS guidance offering relief from estimated tax penalties for failure to accurately calculate tax on deem... Read More

Section 1291 Excess Distribution Calculations for PFIC Tax and Interest Reporting
Extrapolating PFIC Information From Fund Statements and Reporting on Form 8621
June 19, 2018 CPE, EA Download
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This course will provide tax advisers with a detailed analysis of Section 1291 reporting including how to perform the onerous calculations and determine available elections to ease the burden. The panel will go beyond the basics to provide examples of PFIC disclosures on fund statements and illustra... Read More

Deemed Repatriation of Deferred Foreign Earnings: Calculating Accumulated E&P and Transiti...
Determining U.S Shareholders, Cash vs. Non-Cash Positions, Netting Provisions, and Mechani...
February 21, 2018 CPE, EA CPE On-Demand, Download
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This course will provide tax advisers with a practical guide to the deemed repatriation provisions of the new tax reform bill, with a focus on the specific compliance aspects of the requirement to recognize all post-1986 deferred foreign source income. The panel will go beyond the basics of what the... Read More

Tax Reform and U.S. Foreign Reporting for Individuals: New Cross-Border Repatriation and I...
Navigating Participation Exemption System, GILTI Inclusions, Intangible and Passive Income...
February 15, 2018 CPE, EA CPE On-Demand, Download
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This course will provide tax advisers and compliance professionals with a critical first look at the practical impact of the new tax overhaul bill on U.S taxpayers with foreign income and tax reporting obligations. The panel will examine the major changes the new law imposes on calculating and repor... Read More

Form 8854 Exit Tax Calculations and Reporting: Minimizing the IRC 877A Expatriation Tax
Determining Covered Expatriates, Navigating the Mark-to-Market Tax on Unrealized Gains, Re...
October 26, 2017 CPE, EA Download
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This course will provide tax advisers and compliance professionals with a practical guide to the calculations and reporting requirements needed for U.S. taxpayers and exiting green card holders. The panel will discuss the rules of Section 877A, as well as strategies for minimizing the impact of expa... Read More

Foreign Personal Holding Company Income Reporting: Mastering Subpart F Inclusions and Deem...
Navigating Foreign Tax Credit Passive Buckets, Look-Through Recharacterizations, and More
May 11, 2017 CPE, EA Download
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This course will provide tax advisers with a deep exploration of the reporting of income from and ownership of a foreign personal holding company. The panel will identify the tests for determining whether an investment qualifies as a FPHC, outline what qualifies as foreign personal holding company i... Read More

Income Tax Treaty Interpretation and Practice for Tax Professionals: Claiming and Reportin...
October 27, 2015 CPE, EA Download
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This course will provide tax advisers, professionals and preparers with a solid overview and explanation of key income tax treaty provisions needed to determine whether their individual clients may take treaty-based return positions. The speakers will enable advisers and preparers to complete IRS Fo... Read More