Strategies to Recharacterize Gain from Certain Stock Sales with Untaxed Foreign Earnings
Recording of a 110-minute CPE webinar with Q&A
This webinar will review the relevant rules under the new quasi-territorial regime, the remaining types of untaxed foreign earnings, and the basics of Section 1248 and Section 245A. Our panel of multinational tax practitioners will explain planning strategies to use untaxed foreign earnings to recharacterize gain from the sale, or deemed sale, of foreign corporation stock as a deemed dividend that may be eligible for the Section 245A dividends received deduction.
Outline
- Overview of the quasi-territorial system
- Section 1248 and untaxed E&P
- Section 311(b) distributions
- Section 964(e) stock sales
- Section 245A dividends received deduction
Benefits
The panel will cover these and other critical issues:
- Overview of the quasi-territorial system, subpart F and GILTI
- Explaining the types of untaxed E&P after the enactment of the Tax Cuts and Jobs Act
- Historical background and mechanics of Section 1248
- Using untaxed E&P to recharacterize gain from certain Section 311(b) distributions
- Mitigating tax on Section 964(e) stock sales
- Utilizing Section 245A DRD to reduce tax
Faculty
Bona Chung
Manager
Ernst & Young
Ms. Chung advises multinational clients on tax consulting, planning, and structuring issues in connection with... | Read More
Ms. Chung advises multinational clients on tax consulting, planning, and structuring issues in connection with cross-border business operations and transactions. Particularly, she focuses on outbound tax issues, including the U.S. anti-deferral rules (e.g., subpart F, GILTI, and PFICs), cash repatriation, foreign tax credits, and section 367 issues.
CloseAndrew G. Mirisis
Attorney
Freeman Law
Mr. Mirisis is a multi-disciplined tax attorney with over a decade of public and private sector experience. He relies... | Read More
Mr. Mirisis is a multi-disciplined tax attorney with over a decade of public and private sector experience. He relies on that experience to provide advice and counsel his clients and to reach practical and cost-effective solutions.
CloseNick Zemil
Director
PwC
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on... | Read More
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on outbound transactions. Prior to joining PwC's Washington National Tax Services group, he was an associate at an international law firm where his practice focused on cross-border tax controversy issues ranging from the audit stage through litigation. While attending the University of Virginia School of Law, Mr. Zemil was on the editorial board of and was a contributor to the Virginia Tax Review.
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