About the Course
Introduction
This course will provide tax advisers with a practical overview of Subpart F tax treatment of controlled foreign corporations (CFCs). The panel will detail in plain language specific areas of Subpart F, including the recent changes made by the One Big Beautiful Bill Act (OBBBA), the final and proposed regulations, and foreign information reporting requirements on Form 5471.
Description
The Subpart F rules require U.S. shareholders of CFCs to treat certain types of income as taxable in the current year. These calculations have long presented challenges to tax advisers serving clients with CFC holdings. Most recently, OBBBA made significant changes to Subpart F inclusions. Under OBBBA, the income inclusion is pro-rated based on the time period the CFC shareholder held the stock. Prior to OBBBA, a shareholder's income inclusion was determined based on ownership on the last day of the CFC's year. Additional modifications impacting Subpart F inclusions, including the reinstatement of Section 958(b)(4) limiting downward attribution of stock and New 951B anti-deferral rules, were also added by OBBBA.
Continually updated legislation adds complexity to an already challenging regime. Tax advisers must also know whether the new rules create new filing obligations to avoid severe penalties for foreign information reporting noncompliance.
Listen as our authoritative panel of international tax practitioners reviews the Subpart F rules and provides a practical guide to the specific CFC ownership and reporting obligations.
Presented By
Mr. Samtoy specializes in international tax consulting and compliance services. He has experience serving private equity clients, high net worth individuals, and closely held businesses across a variety of industries. Mr. Samtoy helps private equity clients with investor documentation, withholding, structuring and reporting offshore investments, and FATCA and CRS compliance. He is familiar with identifying and documenting the FATCA and CRS status of internal entities as well as filing reports with the IRS and a number of Model 1 IGA jurisdictions to report investors as required. For high-net-worth individuals and families, John assists with planning and structuring for inbound investments as well as immigration to the US. Mr. Samtoy addresses the tax considerations for individuals who are beneficiaries of foreign trusts, including the DNI and UNI calculations, as well as the required reporting on Forms 3520 and 3520-A. He assists closely held businesses with structuring their international operations and export planning, including advising on IC-DISC structures and foreign-derived intangible income (FDII). Mr. Samtoy is also experienced in various international tax compliance areas, including the various foreign asset disclosure requirements and foreign trust and estate reporting. He has presented, as a faculty member, at a number of continuing education events attended by other professionals that covered international tax compliance issues such as determining foreign tax credits, Form 5471 and Form 5472 reporting, the section 962 election for individuals, and global intangible low taxed income (GILTI).
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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
Tuesday, December 9, 2025
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. Subpart F's CFC Rules
II. OBBBA's modifications to Subpart F
III. Strategies to mitigate the effects of the downward attribution rules
IV. GILTI/NCTI – Code § 951A
V. Tax planning strategies and pitfalls
VI. The high-tax Subpart F and GILTI opt-out elections
VII. Key takeaways
The panel will discuss these and other important topics:
- How OBBBA affects Subpart F income
- Constructive ownership tests in CFCs, including downward attribution rules
- How the Subpart F changes run counter to the tax law's general aim to convert to more territorial taxation of U.S. taxpayers as opposed to global-based taxation
- Treatment of earnings invested in U.S. property
Learning Objectives
After completing this course, you will be able to:
- Determine new ownership inclusion rules after OBBBA
- Distinguish the tax provisions under Subpart F from the GILTI/NCTI provisions
- Identify changes to downward attribution rules made by OBBBA
- Ascertain whether income is Subpart F income and the tax consequences if income is classified as Subpart F income
- Decide the best way to repatriate income and to pay taxes on the repatriation of foreign untaxed earnings
- 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, deferred foreign-source income, earnings and profits, controlled foreign corporations, specified foreign corporations, and repatriation of deferred foreign earnings; familiarity with accumulated cash and non-cash retained earnings and profits and netting of earnings and profits positions
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 .
