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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, June 11, 2020

  • schedule Time

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

  • timer Program Length

    110 minutes

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).

$197.00
CPE
ALL

This course will weigh the pros and cons of holding structure choices for foreign investments made by U.S. taxpayers. Our panel will explore the tax impact of entity choice as well as relief available for advisers working with taxpayers with global income.

Faculty

Patrick J. McCormick
Partner
Rimon, P.C.

Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.

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Alison N. Dougherty
Managing Member
Googolplex Tax, LLC

Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and foreign corporations, partnerships, LLCs, individuals, and trusts. She specializes in U.S. international tax reporting and compliance with the preparation and review of the U.S. federal Forms 5471, 926, 8992, 8993, 5472, 8865, 8858, 8621, 8804, 8805, Schedules K-2 and K-3, 1116, 1118, 1042, 1042-T, 1042-S, 8832, 8833, 2555, 3520, 3520-A, 5713, 1120-F, 1040-NR, 8288, 8288-A, 8288-B, 8233, 8840, 8843, 8854, 8938, and FBAR. Ms. Dougherty has extensive experience working with U.S. businesses and individuals with outbound activities in foreign countries. She has also worked with foreign companies and nonresident individuals with inbound activities in the United States. Ms. Dougherty has significant experience with U.S. nonresident withholding tax, foreign partnership withholding tax, and FIRPTA withholding tax. She has managed U.S. tax compliance and advisory client engagements for U.S. C corporations, S corporations, partnerships, LLCs, U.S. individuals, U.S. trusts, foreign corporations, foreign partnerships, foreign LLCs, nonresident individuals, and foreign  trusts. 





Ms. Dougherty is a CPA and a tax attorney with more than 15 years of combined experience in public accounting, the practice of law, and corporate industry. She was previously a tax partner in a large regional public accounting firm in the Washington, DC area. Ms. Dougherty has served clients in various industries including technology, U.S. government contracting, commercial services, telecommunications, real estate, investment partnerships, commodities, high net worth individuals, and family offices. She has also served as a technical resource to other CPAs, accountants, tax professionals, public accounting firms, attorneys, and law firms.  

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Description

U.S. taxpayers are increasingly engaging in activities abroad. The most obvious considerations are whether to form the entity in the U.S. or another country and what type of entity to choose. Adding to the complexity of the decision are the many types of relief available for the taxation of foreign income in the U.S.

A U.S. entity pays tax on worldwide income while a foreign entity pays tax only on U.S. source income. Before tax reform, U.S. shareholders were taxed on Subpart F income (certain passive income and related party transactions) earned by CFCs. Now in addition to Subpart F taxation, Section 951A, GILTI, imposes a tax on net tested income earned by foreign companies. To ease taxation, Section 250A provides domestic corporations with a 37.5% tax deduction for FDII and a 50% deduction for GILTI. This creates an effective tax rate of 10.5% for GILTI and 13.125% for FDII. Additionally, there are benefits of foreign tax credits. Weighing the taxation on worldwide income against the benefits and burdens of being a foreign entity is complex.

Holding the investment individually seems to be a good idea when coupled with the 962 election to take advantage of the lower corporate rates. However, individuals aren't eligible for Section 959 relief from the second level of taxation when assets are distributed.

Listen as our panel of experts explains U.S. taxation of foreign income, anti-deferral rules including GILTI, Subpart F, and PFIC, and relief available by way of Section 962, foreign tax credits, and international treaties to help advisers make the best entity choice for businesses with earnings outside the U.S.

Outline

  1. U.S. taxpayers defined
  2. Foreign entities
    1. Default classifications and electing out
    2. Subpart F
    3. PFICs
    4. GILTI
  3. Treaty provisions
  4. U.S. business entities
    1. PTEs and C corporations
    2. Section 959 relief from double taxation
  5. Holding as individual
    1. Sec 962 election to be taxed as corporation
  6. Foreign reporting requirements

Benefits

The panel will review these and other critical issues:

  • When being taxed in the U.S. on worldwide income may be the best choice
  • When to elect to be taxed at the corporate rate under Section 962
  • What treaty relief is available for double taxation
  • When non-tax considerations outweigh tax benefits
  • How foreign tax credits impact the choice of entity

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify the U.S. default classifications for foreign entities
  • Ascertain when an individual may want to make the election under 962
  • Determine who is a U.S. taxpayer
  • Decide what relief is available under international treaties

  • 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 pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

Strafford Publications, 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

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