Subpart F and PFIC Regulations for U.S. Investors and Domestic Funds
Calculating Subpart F and PFIC Inclusions, Partner-Level PFIC Elections, IRC Sec. 1248, CFC and PFIC Overlap Rules
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers guidance for calculating Subpart F and passive foreign investment company (PFIC) inclusions and final tax rules and regulations. The panel will discuss key provisions of the final rules, the impact on U.S. investors who own interests in foreign corporations through domestic partnerships, changes to Subpart F inclusion rules, partner-level PFIC elections, IRC Sec. 1248 treatment of domestic partnerships, controlled foreign corporation (CFC) and PFIC overlap rules, and other key issues.
Outline
- Subpart F regulations
- Key components of Subpart F anti-deferral regime
- Determining Subpart F income
- Reporting Subpart F income on Form 5471
- Best practices for ensuring accurate reporting of Subpart F income
- PFIC regulations
- PFIC treatment, purging, and deemed distribution rules
- Reporting requirements and inclusions
- Main issues and pitfalls to avoid in reporting and preparing required tax forms
Benefits
The panel will review these and other key issues:
- What are the tax compliance challenges for U.S. persons owning CFCs?
- What are the key provisions and challenges of the Subpart F and PFIC rules?
- What are the challenges in determining and calculating Subpart F and PFIC income?
- What are the main issues and pitfalls to avoid in reporting and preparing the required tax forms?
Faculty
Einav Axler
Attorney
Fenwick & West
Ms. Axler advises on a broad variety of domestic and international tax matters. Prior to joining Fenwick, she was... | Read More
Ms. Axler advises on a broad variety of domestic and international tax matters. Prior to joining Fenwick, she was an associate in an Israeli office of one of the big-four accounting firms where she advised on international tax considerations for multinational clients.
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Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
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