Domesticating Individually-Owned Controlled Foreign Corporations Under Current Tax Law

U.S. tax reform significantly changed the rules governing U.S. persons with non-U.S. businesses and investments. Non-corporate U.S. shareholders of foreign corporations are subject to increased taxes, and tax professionals and advisers must understand complex new CFC rules and methods of domesticating and restructuring foreign corporations to avoid any unforeseen tax liability.

U.S. individuals, trusts and non-corporate shareholders of foreign corporations can limit, or in some cases avoid, the impact of the new outbound tax regime. New U.S. tax law provides complex provisions targeting U.S. multinationals doing business abroad, such as the transition tax on deferred foreign income, GILTI and other regulations impacting U.S. shareholders of foreign corporations. Domesticating or restructuring CFCs can limit the impact of the new tax regime and provide tax savings for U.S. taxpayers.

Tax professionals and advisers must reexam existing structures of foreign corporations owned by U.S. shareholders and understand the application of new tax rules to ensure effective tax planning for U.S. taxpayers.

Listen as our panel discusses new tax rules governing U.S. persons and non-corporate shareholders with non-U.S. businesses and investments and the legal challenges and available planning techniques for domesticating individually-owned CFCs post-tax reform.

I. Tax reform changes to CFC rules

II. Recent IRS regulations and guidance for individual and pass-through shareholders

III. Domestication and restructuring strategies of CFCs for U.S. taxpayers

IV. Best practices to minimize unforeseen tax liability

The panel will discuss these and other key issues:

• How does tax reform impact rules governing U.S. persons with non-U.S. businesses and investments?
• What factors must be considered by non-corporate U.S. shareholders of foreign corporations?
• What methods are available for domesticating or restructuring CFCs for U.S. taxpayers?
• How can Section 962 elections ensure tax savings?
• Application of the transition tax and GILTI for purposes of domesticating of a foreign corporation

Learning Objectives

After completing this course, you will be able to:

• Recognize the impact of tax reform on rules governing U.S. persons with non-U.S. businesses and investments
• Ascertain methods for domesticating or restructuring individually-owned controlled corporations for U.S. taxpayers
• Understand the advantages of Section 962 elections for purposes of domesticating a foreign corporation
• Recognize the impact of broadened attribution rules, transition tax, and GILTI on domesticating or restructuring CFCs

• 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.

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