BarbriSFCourseDetails
  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Foreign Branches, QBUs, and Disregarded Entities: Foreign Tax Credits, Anti-Hybrid Rules, and Planning Strategies

$197.00

This course is $0 with these passes:

CPE
ALL
  1. keyboard_arrow_leftBack
BarbriPdBannerMessage

About the Course

Introduction

This course will explain foreign branches' tax considerations, including what constitutes a foreign branch and its U.S. reporting obligations, calculating foreign branch income and the related foreign tax credit, and the recent 267A anti-hybrid regulations.

Description

A U.S. company can conduct business through a branch in another country or through a foreign entity that is disregarded in the U.S. Generally, a foreign branch is a trade or business operated in a foreign country that maintains its own set of books and records. Although Section 989 defines a foreign branch as a qualified business unit, whether or not it is a trade or business is a facts and circumstances determination.

Income or loss from a foreign branch is reported on a U.S. consolidated income tax return. This can provide substantial benefits to the group when the branch is reporting losses. Dual losses--deducting the same loss in both countries--are prohibited. Reporting income provides additional complexities. Allocation and reallocation rules for foreign branch income must be analyzed to calculate the allowable foreign tax credit. Foreign branch income is subject to a 21 percent tax rate and is ineligible for the Section 250 FDII deductions which yield a 13.125 percent effective tax rate.

Listen as our panel of foreign tax experts explains the tax considerations of operating a foreign branch, including planning strategies to lower the overall tax burden of multinational trade or businesses. Furthermore, Section 267A contains branch payment rules and branch payment mismatch rules that international tax practitioners must understand.

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
Carly Steren
International Tax Manager
Armanino, LLP

Ms. Steren International Tax Manager at Armanino, LLP

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 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

    Thursday, October 17, 2024

  • schedule

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

  1. Foreign branches: overview
  2. Foreign branch loss recapture under Section 91
  3. Subpart F and GILTI
    1. Section 954(d)(2) branch income rules
    2. GILTI and Subpart F high-tax exceptions
  4. Foreign tax credit
  5. Anti-hybrid rules
  6. Form 8858 reporting
  7. Planning strategies

The panel will review these and other critical issues:

  • What constitutes a foreign branch?
  • Who is required to file Form 8858 and Schedule M?
  • What is a branch mismatch payment under Section 267A?
  • What are the differences between a foreign subsidiary and a foreign branch?

Learning Objectives

After completing this course, you will be able to:

  • Identify specific examples of foreign trade or businesses
  • Determine how to allocate foreign branch income to determine the foreign tax credit
  • Decide who should file Form 8858, Information Return of U.S. Persons With Respect to Foreign DREs and Foreign Branches
  • Ascertain specific taxation differences between foreign subsidiaries and foreign branches
  • 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 public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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 .