IRC 163(j) Interest Deduction Limits for Controlled Foreign Corporations: Planning & Calculations
ATI Computation, CFC Group Election, Treatment of Tiered CFCs, Addback Rules
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers serving clients with controlled foreign corporations (CFCs) with a detailed and practical guide to the new Section 163(j) business interest deduction limitation rules--part of the 2017 tax reform law--as they apply to foreign corporations and their U.S. shareholders. The panel will discuss the CFC group election and potential benefits of making the CFC group election, as well as detail the mechanics of calculating adjusted taxable income (ATI) for CFCs and their U.S. shareholders.
Outline
- Contrasting new Section 163(j) rules with the prior Section 163(j) rules
- Small business exception
- Calculating ATI to arrive at the 30% deduction limitation
- Application of Section 163(j) to CFCs and their U.S. shareholders
- The CFC group election and the corresponding benefits
- Application of Section 163(j) to foreign persons with effectively connected income
Benefits
The panel will review these and other relevant topics:
- The impact of new Section 163(j) on CFCs and their US shareholders
- Critical provisions of the recently proposed Treasury regulations
- Specific exceptions to the application of new Section 163(j)
- How to calculate ATI for purposes of determining the Section 163(j) limitation
- CFC group election and mechanics
Faculty
Sean Dokko, J.D., LL.M.
Managing Director, National Tax Office - International Tax Services
BDO USA
Mr. Dokko focuses on international tax planning and consulting for both inbound and outbound clients. He has experience... | Read More
Mr. Dokko focuses on international tax planning and consulting for both inbound and outbound clients. He has experience in structuring and implementing tax efficient foreign holding company structures, IP migrations, cross border restructurings, foreign tax credit planning, implementing strategies to minimize subpart F income, and analyzing income tax treaties. In addition, Mr. Dokko is responsible for analyzing and addressing technical issues related to the various international tax provisions that were included as part of the Tax Cuts and Jobs Act such as the Section 965 transition tax, global intangible low-taxed income and the associated Section 250 deduction, the Section 250 deduction for foreign derived intangible income, and the base erosion and anti-abuse tax. As part of the National Tax Office, he is responsible for assisting the firm’s offices with analyzing complex international tax issues and reviewing international tax technical advice provided to the firm’s clients.
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Chip Morgan, JD
International Tax Partner
BDO USA
Mr. Morgan has focused his career on international tax for over 30 years. He has been an international tax services... | Read More
Mr. Morgan has focused his career on international tax for over 30 years. He has been an international tax services partner with two of the Big Four firms, where he advised clients across a broad range of industries, geographies and transactions. In addition, he gained industry experience as Tax Vice President for a semiconductor manufacturer and a software company, where he implemented and defended international tax structures and worked to keep tax structures aligned with the underlying business operations as they evolved over time. He has worked in New York, Brussels, San Jose and Los Angeles and has assisted companies ranging from startups to very large, mature enterprises. He has deep technical knowledge, combined with practical hands-on experience.
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