Subpart F, CFCs, and PFICs (Completed)
Date: Tuesday, June 8, 2021
Instructor: Jonathan D. Grossberg
| Begin Time: |
9:00am Pacific Time
10:00am Mountain Time
11:00am Central Time
12:00pm Eastern Time |
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC |
|
Subpart F has been the backbone of United States international tax law since its enactment in 1962 and remains so today even after the changes provided by the Tax Cuts and Jobs Act. Planning around and legally avoiding Subpart F income inclusions is a fundamental part of international tax planning for any United States corporation with significant international subsidiaries and operations.
Who Should Attend
Professionals in public practice, industry, government, and education who advise, research, or otherwise engage with U.S. corporations with foreign subsidiaries.
Topics Covered
- Defining and classifying an entity as a controlled foreign corporation (CFC)
- Categories of foreign base company income: foreign personal holding company income, foreign base company sales income, foreign base company services income
- Allocation of deductions to foreign base company income
- Determining Global Intangible Low-Taxed Income (GILTI)
- Indirect repatriation of CFC Earnings
- Deemed paid credits for Subpart F Income and GILTI
- Classification of a personal foreign investment company (PFIC)
- Section 1291 Tax and Interest Regime
- Section 1295 QEF Election
- Section 1296 Mark-to-Market Regime
Learning Objectives
- Describe and classify an entity as a CFC
- Recognize how to determine whether a source of income is foreign base company income
- Identify and apply the test for classifying an entity as a PFIC
Level
Intermediate
Instructional Method
Group: Internet-based
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
Basic knowledge of United States international tax law.
Advance Preparation
None
