International Provisions of the Tax Cuts and Jobs Act 2017 - Webinar - MCLE BY BHBA

Working with the GILTI. Foreign taxes, distribution, dividend, tax on the U.S. individual ultimate owner, total burden, combined tax rate. Domestic C-Corp, election for GILTI, foreign tax credit.
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International Provisions of the Tax Cuts and Jobs Act 2017: Working and Planning with the Final GILTI Regulations. On June 14, 2019, the Internal Revenue Service and Department of Treasury issued final regulations under the Global Intangible Low-Taxed Income (“GILTI”) provisions of the Internal Revenue Code. Broadly speaking, GILTI eliminates U.S. Federal income tax deferral and currently taxes the foreign earnings of U.S. controlled foreign corporations in excess of a fixed (10%) return on depreciable tangible assets. GILTI is one of several closely integrated provisions of TCAJA 2017 that radically changed the pre-2018 taxation of earnings of foreign corporations with U.S. owners.

Our panel and moderator will survey the new international tax regime applicable to outbound transactions, outline the formulaic determinations under GILTI, explain and illustrate the principal features of the recently issued final regulations, including the treatment of U.S. persons holding shares of foreign corporations through domestic partnerships, the use of “high tax exception” to subpart F income inclusions, the proposed GILTI high tax exception and the effective use of the Section 962 (fictional domestic holding company) election. The panel will also consider GILTI planning strategies for U.S. individuals in addition to the fictional domestic holding company election.

As final regulations are issued under the internationally relevant divisions of TCAJA 2017, the Tax Section intends to present additional webinars. Also check our website for short videos (5 to 10 minutes) on tax practice developments.

Speakers:
Thomas M. Giordano-Lascari, Esq., Partner, Karlin & Peebles, LLP
Maria-Soledad Otero, Esq., Partner, Karlin & Peebles, LLP
Moderator: William K. Norman, Esq., Partner, Ord & Norman

CATEGORY: Taxation

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