Description
The GILTI provisions and expanded Subpart F rules significantly impact U.S. owners of foreign corporations. Tax professionals must recognize implications and potential opportunities for U.S. persons owning foreign corporations under recent IRS guidance and current tax law.
The Subpart F rules require "U.S. shareholders" of CFCs to treat certain income types as taxable in the current year. Section 250 adds a layer of current income inclusion for CFC shareholders on global "intangible income" and provides a deduction that reduces the effective tax rate on the included income.
The repeal of Code Sec. 958(b)(4) forces certain taxpayers to include in gross income amounts under Subpart F and GILTI attributable to foreign corporations that are CFCs, even though they may have limited access to critical items to determine whether such foreign corporations are CFCs and their inclusion amounts.
Rev Proc 2019-40 provides relief to certain U.S. persons who own stock in certain foreign corporations by limiting the inquiries they must make to determine whether certain foreign corporations are CFCs. It also offers particular unrelated minority U.S. shareholders the ability to rely on limited information to calculate Subpart F and GILTI inclusions without detailed financial statement information.
Listen as our authoritative panel of international tax practitioners reviews the Subpart F rules and GILTI provisions and provides a practical guide to determining CFC ownership and reporting obligations for U.S. persons owning foreign corporations.
Presented By
Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for international individuals and businesses, identifying international tax incentives and advising multinational businesses on establishing a U.S. presence. Additionally, he is heavily relied on by his clients to navigate inbound and outbound practices, including pre-immigration planning for individuals, and more.
Mr. Juarez leverages more than 24 years of experience to provide tax consulting and compliance services to multinationals, private equity funds, high net worth individuals, and closely held businesses across various industries. Mr. Juarez specializes in international tax issues for both outbound and inbound clients. This includes structuring overseas investments, review of foreign information filings, subpart F, global intangible low-taxed income (GILTI), foreign tax credit opportunities, cross border reorganizations, passive foreign investment companies (PFIC), withholding tax, and more.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Tuesday, July 8, 2025
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. Treatment of U.S. persons owning foreign corporations
II. IRS guidance and key takeaways
III. U.S. tax challenges under Subpart F
IV. U.S. tax challenges under GILTI
V. Best practices for ensuring accurate reporting and compliance
The panel will review these and other key issues:
- Key tax compliance challenges for U.S. persons owning foreign corporations
- Recent IRS regulations and guidance for U.S. taxpayers
- Expanded definition of a CFC and U.S. shareholder
- Expansion of Subpart F and key challenges under new tax law
- Challenges under Section 951A GILTI rules for U.S. taxpayers
- Tax planning and methods to ensure accurate reporting and compliance
