BarbriSFCourseDetails
  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

GILTI High-Tax Exclusion: Sections 951A and 954 Rules for Individual and C Corporation Shareholders

Treatment of CFC income, Reporting Requirements, Planning Techniques to Defer or Reduce GILTI Tax, and More

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
  1. keyboard_arrow_leftBack
BarbriPdBannerMessage

Description

The significant expansion of the application of Subpart F and the addition of an inclusion rule for CFC income--the GILTI rule under tax reform continues to cause complexities for taxpayers and their counsel.

GILTI is not limited to intangible or low-taxed income. It generally consists of a CFC's net income, less Subpart F income, a 10 percent return on depreciable tangible assets, and a few other exclusions. A U.S. person who is a shareholder owning at least 10 percent of a CFC is subject to U.S. federal income tax on a share of the CFC's GILTI under IRC Section 951A. Individuals can experience higher tax rates on GILTI compared to domestic C corporations.

Also, the IRS issued regulations to address the treatment of income subject to high foreign tax rates. The regulations highlight aspects of the GILTI high-tax exclusion and conform them with the Subpart F high-tax exception. They also provide for an election under Sec. 954(b)(4) for both Subpart F income and tested income.

Listen as our panel provides tax professionals with guidance on the challenges of the GILTI provisions under the new tax law. The panel will discuss GILTI and the Section 250 deduction--particularly for individual taxpayers--and provide tax planning tips to minimize the tax liability of taxpayers with CFC interests.

Presented By

Adam Chesman
Senior Director, Cross-Border Mergers and Acquisitions Tax Leader
RSM US, LLP

Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and audit, with particular emphasis on structuring domestic and cross-border mergers and acquisitions, spin-off transactions, post-merger integrations, debt restructurings, bankruptcy workouts, and application of the consolidated return regulations.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Sam Heberton
Senior Tax Manager - International Tax
Bennett Thrasher, LLP

Mr. Heberton is a Senior Tax Manager in Bennett Thrasher’s Tax practice, focusing primarily on income tax services and tax planning services for international taxpayers.He has experience in public accounting, including Big 4 experience; experience with business entities in the telecom, real estate, retail, manufacturing & distribution, SaaS, healthcare, and the professional services industries; and experience with US individuals and expatriates.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Credit Information

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

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

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


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, December 10, 2024

  • schedule

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

  1. Overview of Section 951A
  2. Prior treatment of CFC income and reporting requirements
  3. C corporation vs. Individual taxpayers and the application of GILTI rules
  4. GILTI high-tax exclusion
  5. Methods to defer or reduce the impact of GILTI for individuals, trusts, and non-C corporation U.S. shareholders

The panel will review these and other relevant topics:

  • Determining whether a taxpayer is subject to GILTI tax under Section 951A
  • Calculating GILTI on CFC income
  • GILTI high-tax exclusion
  • Recognizing the reporting requirements and possible credits or deductions
  • Tactics to defer or minimize the GILTI tax

Learning Objectives

After completing this course, you will be able to:

  • Identify foreign holdings and income subject to GILTI
  • Understand the differences between the prior treatment of CFC income and Section 951A
  • Determine how to calculate tax on GILTI
  • Ascertain methods to defer or reduce the GILTI tax
  • Recognize the impact of recent IRS regulations for GILTI high-tax exclusion
  • 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.

BARBRI 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

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

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .