Subpart F Income Rules and Sections 956, 958, and 1248: Reporting Challenges of Controlled Foreign Corporations
Recording of a 110-minute CPE webinar with Q&A
This course will provide professionals with a solid foundation on defining a controlled foreign corporation (CFC) and a "U.S. shareholder," under the rules of Subpart F. The panel will prepare corporate tax managers and advisers to master tax reporting challenges by drilling down into different types of Subpart F income and allowable exclusions, identifying the tax consequences of repatriating a U.S. shareholder-owned foreign corporation's earnings to the United States, and describing "earnings and profits" for these purposes.
Outline
- Identify the definition of a CFC, as well as any associated terms such as "U.S. shareholder"
- Recognize the different types of Subpart F income, as well as allowable exclusions
- Identify the tax consequences of repatriating a U.S. shareholder-owned foreign corporation's earnings to the U.S., and describe E&P for these purposes
Benefits
The panel will analyze and tackle these and other relevant topics:
- Constructive ownership tests in CFCs
- Exclusions from foreign base company income under Subpart F and related regulations
- Treatment of earnings invested in U.S. property
Faculty
Pallav Acharya, CPA, FCA, CGMA
Founder and Owner
CPA Global Tax & Accounting
Mr. Acharya provides tax and accounting services, specializing in international tax and business issues for nearly 3... | Read More
Mr. Acharya provides tax and accounting services, specializing in international tax and business issues for nearly 3 decades. He advises his clients on cross border tax matters, providing services to multinational clients engaged in US inbound or outbound activities. His services include planning, structuring, consulting, compliance and transfer pricing issues. He has worked extensively in the area of IRS overseas voluntary disclosure initiatives and helped clients comply with international tax requirements. He has a wealth of experience in cross border tax planning and compliance issues related to outbound and inbound US businesses as well as non-resident and expatriate individuals.
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Alan Cathcart
Senior Advisor
Alvarez & Marsal Taxand
Mr. Cathcart specializes in corporate and international tax, in particular cross-border mergers and acquisitions.... | Read More
Mr. Cathcart specializes in corporate and international tax, in particular cross-border mergers and acquisitions. His primary area of concentration is structuring international corporate and private equity transactions. With more than 40 years of corporate and international tax experience, he previously was a partner in a Washington, D.C. tax boutique law firm, in addition to having more than 20 years of experience with top-tier accounting firms. He previously spent 12 years with KPMG’s M&A Tax practice, where he most recently served as Senior Director. In that role, he was an experienced adviser to the M&A practice in the Western United States.
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