Domesticating Individually Owned Controlled Foreign Corporations Under Current Tax Law
Restructuring CFCs for U.S. Taxpayers, Mitigating Tax Liability, Section 962 Election, Transition Tax
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This course will guide tax professionals and advisers on the legal challenges and available planning techniques for domesticating individually owned controlled foreign corporations (CFCs) under current tax law. The panel will discuss rules governing U.S. persons with non-U.S. businesses and investments, the impact of tax reform on non-corporate U.S. shareholders of foreign corporations, methods in mitigating increased tax liability, Section 962 elections, and the application of Section 965 for purposes of domestication of a foreign corporation.
Outline
- CFC rules
- IRS regulations and guidance for individual and pass-through shareholders
- Domestication and restructuring strategies of CFCs for U.S. taxpayers
- Best practices to minimize unforeseen tax liability
Benefits
The panel will discuss these and other key issues:
- How does tax reform impact rules governing U.S. persons with non-U.S. businesses and investments?
- What factors must be considered by non-corporate U.S. shareholders of foreign corporations?
- What methods are available for domesticating or restructuring CFCs for U.S. taxpayers?
- How can Section 962 elections ensure tax savings?
- Application of the transition tax and GILTI for purposes of domesticating a foreign corporation
Faculty
Adam Chesman
Senior Director, Cross-Border Mergers and Acquisitions Tax Leader
RSM US
Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and... | Read More
Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and audit, with particular emphasis on structuring domestic and cross-border mergers and acquisitions, spin-off transactions, post-merger integrations, debt restructurings, bankruptcy workouts, and application of the consolidated return regulations.
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Rolando Garcia, JD, CPA
Tax Director
Doeren Mayhew
Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for... | Read More
Mr. Garcia brings more than 20 years of experience to his role in areas such as ensuring U.S. tax compliance for international individuals and businesses, identifying international tax incentives and advising multinational businesses on establishing a U.S. presence. Additionally, he is heavily relied on by his clients to navigate inbound and outbound practices, including pre-immigration planning for individuals, and more.
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Cannot Attend January 7?
Early Discount (through 12/06/24)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.