About the Course
Introduction
This course will provide a practical overview of the controlled foreign corporation (CFC) anti-deferral rules, including the impact of recent legislation under the One Big Beautiful Bill Act (OBBBA). The panel will discuss key revisions made by the Act and its impact on Subpart F inclusions and the anti-deferral regime.
Description
The Subpart F rules generally require U.S. shareholders of CFCs to currently include in gross income certain types of CFC income even where no cash or property was otherwise distributed. The reinstatement of IRC Section 951(b)(4) under OBBBA prevents the inclusion of constructively owned stock under the downward attribution rules, requiring international tax practitioners to revisit stock ownership and reporting obligations for U.S. shareholders of foreign corporations.
Revisions to the pro rata ownership rules are also included in the Act. Before OBBBA, Subpart F income was included in income if a CFC shareholder owned the stock on the last day of the year. Effective Jan. 1, 2026, CFC shareholders must include their pro rata share of Subpart F income if they owned CFC stock at any time during the year. Subpart F income determinations are complex. Now, international tax advisers need to reassess stock ownership and income inclusions in light of recent legislation.
Listen as our authoritative panel of international tax specialists provides a practical guide to determine CFC ownership, tax, and reporting obligations after OBBBA.
Presented By
Mr. Antonov has eight years of experience in federal, state and international income tax. He has worked with multinational businesses and high net-worth individuals, including U.S. subsidiaries of foreign corporations and partnerships. Mr. Antonov provides support on U.S. entity formation and dissolution issues, state and local tax, tax treaty and expat tax issues. He has represented corporate and individual clients before the Internal Revenue Service and state tax departments in connection with tax examinations, and tax controversies.
Mr. Kinder has more than seven years of experience in public accounting. His expertise is in international tax consulting for both corporate and individual taxpayers. Mr. Kinder also has experience in the international sector focusing on cross-border transactions, internal reorganizations and M&A transactions. He contributes articles to the organization’s Thought Leadership series, as well as to outside professional publications.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Date + Time
- event
Monday, August 31, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. General overview of CFC rules
A. Definition of CFC and U.S. shareholder
B. Categories of Subpart F income
C. GILTI/NCTI overview
D. GILTI high-tax exclusion
II. OBBBA legislation impacting Subpart F income determinations
III. Application of CFC anti-deferral rules to domestic partnerships and their partners
The panel will discuss these and other important topics:
- The impact of the repeal of the IRC Section 958(b)(4) on CFC shareholder determinations
- Rules to determine how tested income is taxed for purposes of the GILTI/NCTI high tax exclusion
- Safe harbors for determining non-CFC status
- Pro rata income inclusions for CFC shareholders after OBBBA
Learning Objectives
After completing this course, you will be able to:
- Identify U.S. shareholders subject to the CFC anti-deferral provisions
- Distinguish between Subpart F and GILTI inclusions
- Determine when the CFC anti-deferral rules apply to domestic partnerships and their partners
- Ascertain how the repeal of IRC Section 958(b)(4) impacts CFC shareholder determinations
- 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 a tax or accounting organization, preparing complex tax forms and schedules, such as Form 1116. 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.
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 .
