Deemed Repatriation of Deferred Foreign Earnings: Calculating Accumulated E&P and Transition Tax
Determining U.S Shareholders, Cash vs. Non-Cash Positions, Netting Provisions, and Mechanics of Reporting Repatriation Tax
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to the deemed repatriation provisions of the new tax reform bill, with a focus on the specific compliance aspects of the requirement to recognize all post-1986 deferred foreign source income. The panel will go beyond the basics of what the law says to present compliance professionals with a detailed focus on calculations and the nuts-and-bolts of repatriation, including the leg-work of determining whether a client/entity qualified as a “U.S. shareholder” under the new definitions.
Outline
- U.S. shareholders subject to new foreign provisions
- Definition of “specified foreign corporations”
- Identifying and calculating accumulated E&P subject to deemed repatriation transition tax
- Cash positions
- Non-cash positions
- Netting provisions
- Exclusion for E&P accumulated prior to CFC/SFC status or U.S. shareholder status
- Areas awaiting IRS regulatory guidance
- Calculating tax
- Rates for cash positions
- Rates for non-cash positions
- Calculating eligible foreign tax credits
Benefits
The panel will discuss these and other important topics:
- What differences in definition of U.S. shareholders and specified foreign corporations are included in the new law from prior provisions?
- Identifying what is included in cash and non-cash accumulated E&P positions
- Netting provisions
- What areas and issues will require IRS regulatory guidance?
Faculty
Kimberlee S.P. Murphy, CPA, CGMA, MBA
Partner, Market Leader, International Services
Withum Smith+Brown
Ms. Murphy is Withum’s International Services Market Leader with over 30 years of accounting and tax... | Read More
Ms. Murphy is Withum’s International Services Market Leader with over 30 years of accounting and tax experience, and expertise in International Structuring, FATCA, Transfer Pricing, Inbound and Outbound Transactions, Expatriation Taxation/Global Mobility, and Executive Compensation Planning. She serves on HLB’s International Tax Committee and has co-chaired the HLB North America Tax Services Group. Ms. Murphy has authored articles for numerous local publications and has been a frequent lecturer on tax, business and financial matters to the general public, and professional and business organizations. She coordinates and conducts continuing professional education training on all types of tax issues for the firm’s accountants and outside professionals.
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John Samtoy
Tax Partner
Holthouse Carlin & Van Trigt
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on... | Read More
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on individuals, closely-held businesses, and hedge funds. He has particular expertise in structuring and reporting foreign manufacturing arrangements and foreign holding companies, and is experienced in foreign asset disclosure requirements, as well as foreign trust and estate reporting.
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Mishkin Santa, JD, LLM, TEP
Principal, Director of International Tax
The Wolf Group
Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift &... | Read More
Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift & trust tax compliance, FBAR Assistance, foreign trust tax compliance, exit tax planning, EB-5 investor program, international assignment structuring and planning, offshore voluntary disclosure programs, foreign corporation (Subpart F, Transfer Pricing, E&P Studies), and asset protection planning. His client base includes U.S. citizens living overseas, U.S. nonresidents, EB-5 investors, U.S. domestic individuals and families, international businesses, international based families with investments in multiple jurisdictions and tax residency in multiple jurisdictions, U.S. citizens or residents who are beneficiaries of foreign trusts and who will receive gifts or inheritances from non-US persons, and trustees of trusts with U.S. grantors or U.S. beneficiaries.
