Repatriating Foreign-Source Income for U.S. Taxpayers: Minimizing the Tax Impact of Transferring Offshore Income and Gains
Recording of a 110-minute CPE webinar with Q&A
This course will provide corporate tax professionals and advisers with a practical guide to the challenges and strategies of repatriating foreign income. The panel will outline circumstances in which companies would choose to repatriate, detail steps to minimize tax on repatriation transactions, discuss required tax and financial reporting requirements with repatriation, and offer guidance on the likely impact on repatriation considerations of the new Section 385 regulations and other IRS initiatives to curb offshore tax deferral.
Outline
- Deferral regime for foreign-source income and gains
- Impact of foreign entity classification on repatriation treatment
- Identifying deductions and calculating income on repatriation events
- Strategies for minimizing tax impact of repatriating foreign-source income
- Impact of proposed Section 385 regulations
Benefits
The panel will discuss these and other important issues:
- Creating a repatriation strategy
- Impact of Section 385 proposed regulations on earnings stripping intra-company debt strategies
- Identifying deductions and credits which would reduce taxable income on repatriation
- Repatriation issues for individual and small business taxpayers
Faculty
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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Albert W. Liguori
Managing Director
Alvarez & Marsal Taxand
With more than 20 years of international tax and accounting experience, Mr. Liguori assists multinational... | Read More
With more than 20 years of international tax and accounting experience, Mr. Liguori assists multinational organizations in assessing and improving their global tax strategies. He leads a N.Y. and D.C.-based international tax and transfer pricing team that supports clients on global transactions. He oversees a practice with disciplines spanning from traditional international tax planning, cross-border inter-company arrangements, U.S. inbound planning, mergers and acquisitions, controversy and accounting for income taxes. He previously was a core member of the global tax strategy team of Deloitte Tax, serving as lead adviser on multiple global client transactions. He began his career with Price Waterhouse.
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