Calculating Foreign Sourced Dividends-Received Deduction After Tax Reform
New Section 245A, Intersection of DRD Regime With Other Foreign Income Tax Provisions
Recording of a 110-minute CPE webinar with Q&A
This course will provide corporate tax professionals with a thorough and practical guide to calculating and claiming the dividends-received deduction (DRD) for the foreign-source portion of dividends received from specified 10%-owned foreign corporations by domestic U.S. shareholders of those foreign corporations. The panel will discuss how to identify the guidelines for claiming the deduction, list the qualifications for small business investment treatment, and describe the changes made to DRD calculations by the 2017 tax reform act.
Outline
- Foreign dividends received deduction provisions in general
- Ownership thresholds including "indirect participation"
- Determining what income qualifies as foreign dividends
- Section 245A provisions
- Calculation rules
Benefits
The panel will discuss these and other relevant topics:
- Identifying which types of income are eligible for deduction as "foreign dividends"
- Changes in percentage deduction to correspond with lowered U.S. corporate tax rates
- How the DRD regime intersects with other provisions such as GILTI and the deemed repatriation rules
- Section 245A changes to the foreign DRD rules
- Calculating the deduction
Faculty
Devon M. Bodoh
Partner
Weil Gotshal & Manges
Mr. Bodoh advises clients on cross-border mergers, acquisitions, inversions, spin-offs, other divisive strategies,... | Read More
Mr. Bodoh advises clients on cross-border mergers, acquisitions, inversions, spin-offs, other divisive strategies, restructurings, bankruptcy and non-bankruptcy workouts, the use of net operating losses, foreign tax credits, deficits and other tax attributes, and consolidated return matters.
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Kyle Dawley, J.D., CPA
Principal, Global Tax Services
CliftonLarsonAllen
Mr. Dawley has spent a vast majority of his career focusing on the international tax needs of multinational businesses... | Read More
Mr. Dawley has spent a vast majority of his career focusing on the international tax needs of multinational businesses and individuals. Before CLA, he spent time in Big 4 accounting firms developing strategies and managing complex international business and tax projects which also included transfer pricing optomization. In addition to having expertise in international tax matters, Mr. Dawley has a deep appreciation of general business issues as he spent over a year employed in a biotech start-up company where he was tasked with running their daily operations and long-term vision. He has served clients in a wide-range of industries from both a U.S. inbound and outbound perspective.
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Greg W. Featherman
Principal
KPMG
Mr. Featherman advises KPMG partners, employees and clients on corporate tax matters including domestic and... | Read More
Mr. Featherman advises KPMG partners, employees and clients on corporate tax matters including domestic and international mergers, acquisitions, spin-offs, other divisive strategies, restructurings, bankruptcy and non-bankruptcy workouts, and consolidated return matters. Prior to joining KPMG, he was an associate in the international law firm of Dewey & LeBoeuf LLP. He speaks frequently at seminars and conferences on subjects within his expertise.
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