Section 965 Payment Acceleration Events: Avoiding Triggers, Curable Events
Recording of a 110-minute CPE webinar with Q&A
This course will point out specific actions that accelerate the deferred payment of tax on repatriated earnings under IRC Section 965. Our veteran panel of foreign tax experts will discuss which actions are curable, how to cure these, and identify ways to avoid activities triggering the acceleration of payments due on this substantial deferred tax liability.
Outline
- Overview
- Installment elections and acceleration events
- S corporation shareholder deferral and acceleration events
- Curable events
- Situations where acceleration events may occur
- Best practices
Benefits
The panel will review these and other critical issues:
- Specific events that will accelerate Section 965 tax payments
- How a taxpayer's death, expatriation or other similar events impact Section 965 payment obligations
- How tax implications of acceleration liability differ by entity type when a business is sold
- The party primarily liable for Section 965 payments when a business is transferred
Faculty
Bryan H. Kelly
Partner
Withers Bergman
Mr. Kelly has private practice and Big Four accounting firm experience advising clients on a multitude of tax matters,... | Read More
Mr. Kelly has private practice and Big Four accounting firm experience advising clients on a multitude of tax matters, with an emphasis on the tax considerations relating to cross-border transactions. He advises both U.S.-based and non-U.S.-based multinational organizations across a number of industries, ranging from large, publicly traded companies to start-up ventures, on federal income tax considerations with respect to various inbound and outbound transactions. He has significant experience with inbound investment into the United States. In addition, he regularly coordinates with advisers across multiple jurisdictions to manage the global design and implementation of structuring and restructuring projects.
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Paul Sczudlo
Of Counsel
Withers Bergman
Mr. Sczudlo has over 35 years of experience focused on global planning matters. He is widely recognized for his... | Read More
Mr. Sczudlo has over 35 years of experience focused on global planning matters. He is widely recognized for his practice in cross-border and entertainment tax planning. His clients have ranged broadly from high-net-worth individuals; foreign investors in U.S. real estate and other U.S.-situated assets; Americans with offshore investments, acquisitions and business activities; public and closely-held businesses; and financial institutions. Mr. Sczudlo’s practice emphasizes entertainment taxation; international income taxation; international estate and gift tax planning; international estate administration; international wealth transfer planning; other international planning for high-net-worth individuals; inbound planning for businesses seeking to set up, acquire or dispose of, manufacturing, distribution, licensing or other operations in the U.S.; outbound planning for U.S. businesses establishing or acquiring foreign operations; international tax withholding; and cross-border tax reporting, compliance and controversy issues.
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