BarbriSFCourseDetails
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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Tuesday, January 14, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax professionals with an in-depth discussion of the challenges posed to U.S. businesses that must report their global intangible low-taxed income (GILTI). The panel will discuss how GILTI is calculated and key tax GILTI reporting issues involving IRS Forms 5471, 8992, 8993, and 1118.

Faculty

Michael Dana
Partner
Husch Blackwell LLP

Mr. Dana provides tax and corporate law advice to businesses at all phases of operation, from initial business formation to disposition and all points in between. He advises clients across virtually all areas of operation regarding U.S. federal income tax issues. Mr. Dana has represented U.S.-based, foreign-based, and multinational enterprises, providing advice in connection with acquisitions, distribution structures, and internal reorganizations, including complex crossborder transactions; U.S. Subpart F income and GILTI planning and analysis; foreign tax credit planning and analysis; tax treaty analysis, and other matters related to outbound and inbound U.S. tax planning. His representations have included business structures, operations, and investments by US clients in, or by non-US clients from, Europe, Canada, Latin America and a number of other jurisdictions outside of the U.S. He also works with closely held businesses and their owners to develop and implement tax strategies that protect and enhance corporate value.

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Renan Rodriguez
Associate
Husch Blackwell LLP

Mr. Rodriguez advises businesses on tax and corporate law matters throughout their entire lifecycle, from initial formation to eventual disposition, and everything in between. Additionally, he has focused on representing clients with respect to U.S. federal tax audits, IRS administrative appeals and litigation. Mr. Rodriguez has represented U.S.-based, foreign-based, and multinational enterprises and private equity firms, providing advice in connection with mergers and acquisitions, distribution structures, and internal reorganizations, including complex border transactions; U.S. Subpart F income and GILTI planning analysis; tax treaty analysis; and other matters related to outbound and inbound U.S. tax planning. He has represented U.S. clients investing in or structuring business operations in Latin America, Europe, Canada, and various other jurisdictions outside the U.S., as well as non-U.S. clients investing in the U.S. Additionally, Mr. Rodriguez collaborates with closely held businesses and their owners to create and implement tax strategies that safeguard and maximize corporate value.

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Description

The U.S. imposes taxes on foreign-sourced income of U.S. businesses and individuals, including certain income related to affiliated foreign companies. Tax reform added an inclusion rule for controlled foreign corporation (CFC) income: the GILTI rule. Tax professionals must understand the nuances of the GILTI rules and reporting challenges.

With TCJA's creation of the GILTI anti-deferral regime under IRC Section 951A, all tax professionals serving U.S. businesses operating abroad via CFCs must understand the implications of the GILTI rules and the challenges they pose with regard to reporting GILTI. Since the GILTI rules are recent, sweeping, complex, and are still evolving, reporting the GILTI of a U.S. business is a task beset by uncertainties. The panel will provide tax professionals with guidance on how to navigate GILTI reporting issues involving Forms 5471, 8992, 8993, and 1118.

Listen as our panel provides tax professionals with guidance on the challenges of the GILTI rules. The panel will discuss calculating GILTI and the Section 250 deduction, particularly for individual taxpayers; reporting compliance; and navigating Forms 5471, 8992, 8993, and 1118. The panel will also offer tax planning tips to minimize the tax liability of taxpayers with CFC interests.

Outline

  1. Determining if a U.S. business is subject to the GILTI rules
  2. Steps in determining a U.S. business' GILTI
  3. Reporting GILTI on:
    1. Form 5471
    2. Form 8992
    3. Form 8993
    4. Form 1118

Benefits

The panel will review these and other key issues:

  • Determining whether a taxpayer is subject to GILTI tax under Section 951A
  • Calculating GILTI on CFC income
  • Navigating tax reporting issues on Forms 5471, 8992, 8993, and 1118
  • Recognizing the reporting requirements and possible credits or deductions
  • Impact of final Section 250 regulations
  • Strategies to defer or minimize the GILTI tax

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify foreign holdings and income subject to GILTI tax
  • Differentiate between the prior treatment of CFC income and new Section 951A regime
  • Discern how to net GILTI calculations among multiple CFC holdings
  • Determine how to calculate tax on GILTI

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or professional experience at mid-level within the organization, preparing complex tax forms and schedules. Specific knowledge and understanding of international taxation, deferred foreign-source income, earnings and profits, controlled foreign corporations, specified foreign corporations, and repatriation of deferred foreign earnings; familiarity with accumulated cash and non-cash retained earnings and profits and netting of earnings and profits positions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).