Webcast: Surgent's U.S. Taxation of Foreign Corporations: A Case Study Approach

Overview

This course is a case study designed to provide a comprehensive overview of U.S. taxation of a foreign corporation. Using a specific example, the course will walk through step-by-step mechanics on how to calculate the income inclusions and foreign tax credits under GILTI (Global Intangible Low-Taxed Income), Subpart F andPFIC (Passive Foreign Investment Company) regimes. The case study will further evaluate tax impact of subsequent distributions from the foreign corporation and sales of its stock. A compare-and-contrast approach will highlight the different outcomes of these regimes for individuals and for C corporations, empowering participants to advise their clients on the most tax efficient way to structure their international investments.

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Highlights

• Understand how to approach and analyze the U.S. taxation of foreign corporations
• Using an example, calculate GILTI, Subpart F andPFIC income inclusions for an individual and C corporation
• Determine how much foreign tax credit can be claimed against such income inclusions
• Determine how subsequent dividend distributions from the foreign corporation are taxed
• Calculate capital gain on the disposition of the foreign corporation
• Discuss the impact of Section 962 election
• Compare different outcomes under GILTI, Subpart F andPFIC regimes for individuals and corporations
• Identify basic strategies for managing tax liabilities related to foreign corporations

Prerequisites

A basic understanding of the tax rules relating to individual and corporate income tax

Designed For

Any tax practitioner with clients invested in a foreign corporation

Objectives

• Explain the similarities and differences between GILTI, Subpart F and PFIC regimes
• Understand the mechanics of income inclusions and foreign tax credits available under GILTI, Subpart F andPFIC regimes
• Compare and contrast the overall tax liability under different circumstances
• Identify tax planning opportunities for income from foreign corporations