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Foreign Branches, QBUs, and Disregarded Entities: Foreign Tax Credits, Anti-Hybrid Rules,...
September 21, 2021 CPE, EA CPE On-Demand, Download

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

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

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

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

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

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

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 12, 2021 CPE, EA CPE On-Demand, Download

This course will provide tax advisers with guidance 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 interna... Read More

Foreign Tax Credits for Individuals: Form 1116 Changes, Final and Proposed Regulations
GILTI High-Tax Exception, Limitations and Calculations, Income Baskets, Carryovers
December 10, 2020 CPE, EA CPE On-Demand, Download

This course will provide a practical guide to completing Form 1116 to claim foreign tax credits (FTCs) in the aftermath of recent law changes to the Section 901 credit regime. The panel will outline which foreign taxes are eligible for foreign income tax credits after GILTI, discuss strategies for d... Read More

New GILTI High Tax-Exclusion Final Regulations: Tested Units, Controlled CFC Groups, and R...
November 19, 2020 CPE, EA CPE On-Demand, Download

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) released in July 2020. Our panel of international tax experts will explain how the final regul... Read More