U.S. Foreign Tax Reporting for Individuals: International Repatriation and Inclusion Provisions

The tax consequences of an individual U.S. person holding foreign assets have changed substantially. Recent tax reform and updated regulations contain numerous provisions that have had a dramatic impact on U.S. individuals engaged in international business activities.

New attribution rules have created more CFCs, while the ability to defer foreign earnings has been severely diminished. The GILTI regime subjects certain income to tax at ordinary rates while individuals remain subject to Subpart F rules. Recent regulations issued to clarify areas of uncertainty have created new questions and planning opportunities.

These opportunities include holding structure choices, making the Section 962 election, and taking advantage of treaty provisions and tax credits. Tax advisers serving individual and small business clients with foreign-source income must avoid costly tax consequences by becoming proficient in the latest concepts.

Listen as our experienced panel provides a critical look at the cross-border implications of the latest tax reforms, including steps to take to minimize an individual taxpayer's effective global tax rate.

1. Cross-border provisions and definitions
2. Ownership structures: considerations for residents and NRAs
3. CFCs and GILTI
4. Subpart F income
5. Section 965, repatriation and proposed double-taxation relief
6. Section 962, individual election to be taxed at corporate rates
7. Takeaways and strategies

The panel will discuss these and other relevant topics:

• How the definitions of U.S. shareholders subject to tax on previously deferred foreign-source income have changed
• Critical income inclusion and Section 965 repatriation provisions
• Treatment of foreign passive and intangible income under the new rules
• GILTI and Subpart F income

Learning Objectives

After completing this course, you will be able to:

• Determine the definition of U.S. CFC shareholders
• Distinguish the tax provisions under Subpart F from the GILTI provisions
• Recognize the changes in the treatment of foreign tax credits
• Ascertain new and expanded IRS reporting requirements

• 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 public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Knowledge of, and familiarity with, the foreign-source income tax reporting rules, Subpart F inclusions, Controlled Foreign Corporations determination, Foreign Account Tax Compliance Act and its reporting requirements.

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).