BarbriSFCourseDetails
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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Corporate Tax

Date & Time
  • event Date

    Wednesday, June 14, 2023

  • schedule Time

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

  • timer Program Length

    110 minutes

Credit Information

  • 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).

$247.00
CPE
ALL

This course will provide a practical overview of the controlled foreign corporation (CFC) anti-deferral rules including the 2022 Section 958 final regulations that provide rules with respect to domestic partnerships and their partners. The panel will also discuss some key issues with respect to the repeal of Section 958(b)(4) and the downward attribution rules that can create unexpected CFC status.

Faculty

Sean Dokko
Miscellaneous

Mr. Dokko is a partner in Citrin Cooperman’s International Tax Practice and is based out of the New York office. He practices in all areas of international tax with a focus on inbound and outbound tax planning. He advises clients on U.S. international tax matters, including international tax issues that arise in cross-border M&A, reorganizations, and dispositions. Mr. Dokko has extensive experience in developing, implementing, and reporting tax planning strategies and cross-border restructurings along with advising on issues with respect to U.S. anti-deferral rules, supply chain planning, withholding, tax treaties, financing transactions, and global tax rate reduction. Prior to joining Citrin Cooperman, he was a Principal and Head of Tax at a tax consulting firm in New York City and prior to that, was a Managing Director in the National Tax Office – International of a public accounting firm.

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Brian Waller
Manager, International Tax Services
Citrin Cooperman & Co.

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Description

As part of the Tax Cuts and Jobs Act (TCJA), Section 958(b)(4) was repealed. The repeal of Section 958(b)(4) modified the rules for determining U.S. shareholder and CFC status and thus, increased the number of foreign subsidiaries subject to the CFC anti-deferral provisions.

The Subpart F rules generally require U.S. shareholders of CFCs to currently include into gross income certain types of CFC income even where no cash or property was otherwise distributed. Included as part of the TCJA, Section 951A, global intangible low-taxed income (GILTI), added additional rules and complexity which can subject U.S. shareholders of CFCs to current tax.

The 2022 Section 958 final regulations (T.D. 9960) modified how domestic partnerships and their partners recognize income under the CFC anti-deferral rules. These changes can substantially alter which shareholders include income under CFC anti-deferral rules and how such income is reported on tax filings. Application of the 2022 Section 958 final regulations can also have certain unintended consequences under the passive foreign investment company (PFIC) rules.

Listen as our authoritative panel of international tax practitioners review the CFC anti-deferral rules, detail the downward attributions rules that create unexpected CFC status, explain the treatment of domestic partnerships and their partners, and provide a practical guide to determine CFC ownership, tax, and reporting obligations.

Outline

  1. General overview of CFC rules
    1. Definition of CFC and U.S. shareholder
    2. Categories of Subpart F income
    3. GILTI overview
    4. GILTI high-tax exclusion
  2. Repeal of Section 958(b)(4) issues
    1. Implications to direct or indirect U.S. shareholders
    2. Implications to constructive U.S. shareholders
    3. Form 5471 filing requirements and exceptions
  3. Application of CFC anti-deferral rules to domestic partnerships and their partners
    1. Final section 958 regulations
    2. Proposed PFIC regulations

Benefits

The panel will discuss these and other important topics:

  • Rules to determine how tested income is high taxed for purposes of the GILTI high tax exclusion
  • Compliance issues due to the repeal of section 958(b)(4)
  • Safe harbors for determining non-CFC status
  • PFIC issues that may arise to certain partners when a domestic partnership applies the 2022 Section 958 Final Regulations

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify U.S. shareholders subject to the CFC anti-deferral provisions
  • Distinguish between Subpart F and GILTI inclusions
  • Ascertain how the CFC anti-deferral rules apply to domestic partnerships and their partners
  • Identify foreign corporations that may be treated as CFCs due to the repeal of Section 958(b)(4)

  • 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 a tax or accounting organization, preparing complex tax forms and schedules, such as Form 1116. Specific knowledge and understanding of international taxation, foreign source income, deferred foreign source income, controlled foreign corporations, specified foreign corporations, repatriation of deferred foreign earnings, and treatment of foreign-sourced income received by U.S. taxpayers, familiarity with cash and non-cash retained earnings and profits and global intangible low-tax income (GILTI).

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).