BarbriSFCourseDetails
  1. keyboard_arrow_leftBack

Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Friday, May 9, 2025

  • schedule Time

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

  • timer Program Length

    90 minutes

Credit Information

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

$347.00
CLE
ALL

This course will guide tax professionals and advisers on the legal challenges and available planning techniques for domesticating individually owned controlled foreign corporations (CFCs) under current tax law. The panel will discuss rules governing U.S. persons with non-U.S. businesses and investments, the impact of tax reform on non-corporate U.S. shareholders of foreign corporations, methods in mitigating increased tax liability, Section 962 elections, and the application of Section 965 for purposes of domestication of a foreign corporation.

Faculty

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
Rolando Garcia
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.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio

Description

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. Tax professionals and advisers must understand complex CFC rules and methods of domesticating and restructuring foreign corporations to avoid 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 outbound tax regime. 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 tax regime and provide tax savings for U.S. taxpayers.

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

Listen as our panel discusses 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 under current tax law.

Outline

  1. CFC rules
  2. IRS regulations and guidance for individual and pass-through shareholders
  3. Domestication and restructuring strategies of CFCs for U.S. taxpayers
  4. Best practices to minimize unforeseen tax liability

Benefits

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 a foreign corporation