BarbriSFCourseDetails
  • videocam Live Webinar with Live Q&A
  • calendar_month April 24, 2026 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Taxation of U.S. Persons Owning Foreign Corporations: Strategies for Subpart F and GILTI Inclusions

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About the Course

Introduction

This CLE/CPE course will guide tax counsel and advisers on the implications and potential opportunities for U.S. persons owning foreign corporations under recent IRS guidance and current tax law. The panel will discuss key tax provisions and regulations causing compliance issues for U.S. taxpayers, Subpart F tax treatment of controlled foreign corporations (CFCs), global intangible low-tax income (GILTI), significant tax modifications for U.S. persons owning stock of foreign corporations through domestic partnerships, and best practices for ensuring accurate reporting and compliance.

Description

The GILTI provisions and Subpart F rules significantly impact U.S. owners of foreign corporations. Tax professionals must recognize implications and potential opportunities for U.S. persons owning foreign corporations under recent IRS guidance and in light of the OBBBA.

The Subpart F rules require "U.S. shareholders" of CFCs to treat certain income types as taxable in the current year. Section 250 adds a layer of current income inclusion for CFC shareholders on global "intangible income" and provides a deduction that reduces the effective tax rate on the included income.

The OBBBA modifies and expands international tax law provisions addressing (1) the foreign tax credit calculations, (2) determining a shareholder's Subpart F and GILTI income, (3) the new limit on credits for foreign income taxes attributable to distributions of previously taxed earnings and profits, and (4) updates to the definition of "deduction eligible income." Tax counsel and advisers must have a complete understanding of certain issues and potential pitfalls for taxpayers and methods to maintain compliance.

Listen as our authoritative panel of international tax practitioners reviews the Subpart F rules and GILTI provisions and provides a practical guide to determining CFC ownership and reporting obligations for U.S. persons owning foreign corporations

Presented By

Rolando Garcia, JD, CPA
Tax Director
Doeren Mayhew

Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for international individuals and businesses, identifying international tax incentives and advising multinational businesses on establishing a U.S. presence. Additionally, he is heavily relied on by his clients to navigate inbound and outbound practices, including pre-immigration planning for individuals, and more.

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Todd Juarez
International Tax Director
CBIZ
Credit Information

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

  • CPE credit is not available on recordings.

  • 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

    Friday, April 24, 2026

  • schedule

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

I. Treatment of U.S. persons owning foreign corporations

II. Impact of OBBBA

III. IRS guidance and key takeaways

IV. U.S. tax challenges under Subpart F

V. U.S. tax challenges under GILTI

VI. Best practices for ensuring accurate reporting and compliance

The panel will review these and other key issues:

  • Key tax compliance challenges for U.S. persons owning foreign corporations
  • Recent IRS regulations and guidance for U.S. taxpayers
  • Impact of the OBBBA and planning opportunities
  • Expanded definition of a CFC and U.S. shareholder
  • Expansion of Subpart F and key challenges under new tax law
  • Challenges under Section 951A GILTI rules for U.S. taxpayers
  • Tax planning and methods to ensure accurate reporting and compliance

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 under the new law
  • 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, 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).

BARBRI, 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

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 Barbri-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 .