Foreign Outbound Transaction Planning: Navigating Deferral Under Subpart F and the New IRC Sections 367, 7874, and 385 Regulations
Recording of a 110-minute CPE webinar with Q&A
This course will provide corporate tax advisers with a broad and practical guide to foreign tax planning of outbound transactions. The panel will describe the various deferral structures allowed by the Internal Revenue Code, review the ownership and asset thresholds for “CFC” and “PFIC” status and detail the related reporting requirements for those entities. The panel will also take a critical look at key developments concerning outbound foreign transactions, including the new Anti-Inversion Regulations under Section 7874 and proposed new regulations under Sections 385 and 367(a) and (d).
Outline
- Explanation of Various Structures for Outbound Transactions
- New anti-hybrid rules
- Amended rules applicable to CFCs (“Controlled Foreign Corporations”) and PFICs (“Passive Foreign Investment Companies”)
- Related reporting requirements
- How to Structure Outbound Transfers of Intangibles in light of the newly proposed Regulations issued under Section 367(a) and (d)
- Planning Traps for the Unwary presented by the new Anti-Inversion Regulations and Proposed Section 385 Regulations
- What you need to know about the new U.S. Country-by-Country Reporting Regulations, as well as the evolving international transfer pricing norms being advocated by the OECD in its BEPS initiative
Benefits
The panel will analyze and tackle these and other relevant topics under:
- What are the ownership thresholds, which can trigger the end of taxdeferral treatment of outbound transactions and structures?
- What do the new Section 367 rules mean for goodwill, going-concern value, and other intangible assets?
- What must all international tax planners know about the new U.S. temporary regulations aimed at preventing corporate inversions?
- What impact could the Proposed Section 385 Regulations have on outbound planning—and specifically loans by U.S. –owned entities?
- What tax planning and compliance challenges will the new U.S. country-by-country reporting standards have on outbound transactions?
Faculty
William K. Norman, J.D., LL.M. (Taxation)
Partner
Ord & Norman
Mr. Norman practices as a tax lawyer. He limits his practice to international tax planning and compliance for high net... | Read More
Mr. Norman practices as a tax lawyer. He limits his practice to international tax planning and compliance for high net worth individuals, corporations and joint ventures. He regularly works with U.S. businesses expanding overseas, foreign based businesses establishing operations in the United States, and multinational families on wealth transfer matters. He assists in-house staff of businesses and their outside tax professionals with filings, audits and appeals involving international tax issues and represents individuals in Overseas Delinquent Filings, Voluntary Disclosures and Streamlined Filing Procedures.
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Pamela A. Fuller, JD, LLM
Gremminger Law Firm
Ms. Fuller has broad experience in federal, state, and international tax planning matters. She counsels foreign and... | Read More
Ms. Fuller has broad experience in federal, state, and international tax planning matters. She counsels foreign and U.S. based companies, their executives, and high-net-worth individuals, in structuring their transactions and investments for optimal tax and business results. She is experienced in complex tax issues, including transfer pricing disputes. She helps U.S. persons holding foreign accounts and assets to comply with their U.S. tax filing obligations - including those pertaining to FBAR and FATCA. She frequently publishes in the areas of international tax planning, dispute resolution, capital markets, and comparative securities law.
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