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GILTI High-Tax Exclusion: Sections 951A and 954 Rules for Individual and C Corporation Shareholders

Treatment of CFC income, Reporting Requirements, Planning Techniques to Defer or Reduce GILTI Tax, and More

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

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Tuesday, December 10, 2024

1:00pm-2:30pm EST, 10:00am-11:30am PST

Early Registration Discount Deadline, Friday, November 15, 2024

or call 1-800-926-7926
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This CLE/CPE course will guide tax professionals on the challenges of the global intangible low-taxed income (GILTI) provisions under current tax law and the recent GILTI high-tax exception. The panel will discuss IRS final regulations and the high-tax exception, treatment of controlled foreign corporation (CFC) income, and reporting requirements for individual and C corporation taxpayers subject to GILTI, as well as provide tax planning tips to minimize the tax liability of taxpayers with CFC interests.

Description

The significant expansion of the application of Subpart F and the addition of an inclusion rule for CFC income--the GILTI rule under tax reform continues to cause complexities for taxpayers and their counsel.

GILTI is not limited to intangible or low-taxed income. It generally consists of a CFC's net income, less Subpart F income, a 10 percent return on depreciable tangible assets, and a few other exclusions. A U.S. person who is a shareholder owning at least 10 percent of a CFC is subject to U.S. federal income tax on a share of the CFC's GILTI under IRC Section 951A. Individuals can experience higher tax rates on GILTI compared to domestic C corporations.

Also, the IRS issued regulations to address the treatment of income subject to high foreign tax rates. The regulations highlight aspects of the GILTI high-tax exclusion and conform them with the Subpart F high-tax exception. They also provide for an election under Sec. 954(b)(4) for both Subpart F income and tested income.

Listen as our panel provides tax professionals with guidance on the challenges of the GILTI provisions under the new tax law. The panel will discuss GILTI and the Section 250 deduction--particularly for individual taxpayers--and provide tax planning tips to minimize the tax liability of taxpayers with CFC interests.

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Outline

  1. Overview of Section 951A
  2. Prior treatment of CFC income and reporting requirements
  3. C corporation vs. Individual taxpayers and the application of GILTI rules
  4. GILTI high-tax exclusion
  5. Methods to defer or reduce the impact of GILTI for individuals, trusts, and non-C corporation U.S. shareholders

Benefits

The panel will review these and other relevant topics:

  • Determining whether a taxpayer is subject to GILTI tax under Section 951A
  • Calculating GILTI on CFC income
  • GILTI high-tax exclusion
  • Recognizing the reporting requirements and possible credits or deductions
  • Tactics to defer or minimize the GILTI tax

Faculty

Chesman, Adam
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

Heberton, Sam
Sam Heberton
Senior Tax Manager - International Tax
Bennett Thrasher

Mr. Heberton is a Senior Tax Manager in Bennett Thrasher’s Tax practice, focusing primarily on income tax...  |  Read More

Attend on December 10

Early Discount (through 11/15/24)

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Cannot Attend December 10?

Early Discount (through 11/15/24)

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.

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