Description
The Subpart F rules require U.S. shareholders of CFCs to treat certain types of foreign corporate income as taxable in the current year. The Subpart F rules increase the number of foreign corporations treated as CFCs and catch many more U.S. persons in the Subpart F net. Tax professionals must recognize the resulting U.S. foreign tax information reporting challenges for U.S. persons owning foreign corporations. Advisers need to expand their Subpart F expertise to navigate the two most relevant Subpart F reporting platforms: Form 5471 and Form 1118.
The panel will also compare Subpart F with the GILTI anti-deferral regime. Due to the GILTI anti-deferral regime, a U.S. shareholder of a CFC may even wish to trigger Subpart F income to get out of the GILTI rules because Subpart F income is subject to less stringent U.S. foreign tax credit strictures than GILTI.
Listen as our panel discusses Subpart F rules and provides a practical guide to determining CFC ownership, Subpart F income, and reporting obligations for U.S. shareholders of CFCs with Subpart F income.
Presented By
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.
Ms. Duskis is a Tax Senior Manager and member of the Financial Services Group, with more than 10 years of experience in tax compliance and advisory services. She works with both start-ups and well-established clients with U.S. and foreign operations, and provides service to a broad range of asset managers, their funds and their portfolio companies.
Mr. Mainguy has more than eight years of public accounting experience providing international tax services to clients in a wide range of industries, as well as individuals and publicly traded companies. He has extensive experience working with multinational corporate clients on consulting and compliance projects, including global business model optimization and restructuring projects from the design and feasibility stage through implementation. He also has expertise in U.S. tax issues relating to both inbound and outbound investments, as well as navigating the increasingly complex network of reporting, disclosure, and withholding requirements arising from doing business in a global economy.
-
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).
-
Date + Time
- event
Tuesday, August 20, 2024
- schedule
1:00 p.m. ET./10:00 a.m. PT
- Basic components of the Subpart F anti-deferral regime
- Determining Subpart F income
- Reporting Subpart F income on Form 5471
- Claiming the foreign tax credit for Subpart F income on Form 1118
- Best practices for ensuring accurate reporting of Subpart F income
- Analyzing the high-tax election for Subpart F and GILTI vs. foreign tax credits
The panel will review these and other key issues:
- What are the tax compliance challenges for U.S. persons?
- What are the challenges in determining and calculating Subpart F income?
- What are the main issues and pitfalls to avoid in preparing Forms 5471 and 1118?
Learning Objectives
After completing this course, you will be able to:
- Determine how the definition of U.S. shareholders subject to tax on previously deferred foreign-source income has changed
- Distinguish the tax provisions under Subpart F from the GILTI provisions
- Ascertain whether income is Subpart F income and the tax consequences of classifying income as Subpart F
- 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.
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 .
Related Courses
IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process
Wednesday, December 10, 2025
1:00 p.m. ET./10:00 a.m. PT
Tax Aspects of LLC Drafting: Target Allocations; Key Negotiated Tax Terms in JVAs; Top 10 Tax Mistakes When Drafting Agreements
Thursday, December 4, 2025
1:00 p.m. ET./10:00 a.m. PT
Tax Considerations in Business Entity Selection: Advantages and Disadvantages for Counsel and Advisers
Thursday, November 13, 2025
1:00 p.m. ET./10:00 a.m. PT