Subpart F vs. GILTI: CFC Anti-Deferral Issues
CFC Anti-Deferral Issues
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide a practical overview of the controlled foreign corporation (CFC) anti-deferral rules including the 2022 Section 958 final regulations that provide rules with respect to domestic partnerships and their partners. The panel will also discuss some key issues with respect to the repeal of Section 958(b)(4) and the downward attribution rules that can create unexpected CFC status.
Outline
- General overview of CFC rules
- Definition of CFC and U.S. shareholder
- Categories of Subpart F income
- GILTI overview
- GILTI high-tax exclusion
- Repeal of Section 958(b)(4) issues
- Implications to direct or indirect U.S. shareholders
- Implications to constructive U.S. shareholders
- Form 5471 filing requirements and exceptions
- Application of CFC anti-deferral rules to domestic partnerships and their partners
- Final section 958 regulations
- Proposed PFIC regulations
Benefits
The panel will discuss these and other important topics:
- Rules to determine how tested income is high taxed for purposes of the GILTI high tax exclusion
- Compliance issues due to the repeal of section 958(b)(4)
- Safe harbors for determining non-CFC status
- PFIC issues that may arise to certain partners when a domestic partnership applies the 2022 Section 958 Final Regulations
Faculty
Sean Dokko, J.D., LL.M.
International Tax Partner
Citrin Cooperman
Mr. Dokko is a partner in Citrin Cooperman’s International Tax Practice and is based out of the New York office.... | Read More
Mr. Dokko is a partner in Citrin Cooperman’s International Tax Practice and is based out of the New York office. He practices in all areas of international tax with a focus on inbound and outbound tax planning. He advises clients on U.S. international tax matters, including international tax issues that arise in cross-border M&A, reorganizations, and dispositions. Mr. Dokko has extensive experience in developing, implementing, and reporting tax planning strategies and cross-border restructurings along with advising on issues with respect to U.S. anti-deferral rules, supply chain planning, withholding, tax treaties, financing transactions, and global tax rate reduction. Prior to joining Citrin Cooperman, he was a Principal and Head of Tax at a tax consulting firm in New York City and prior to that, was a Managing Director in the National Tax Office – International of a public accounting firm.
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