Description

<p>As a boutique international tax firm, we&rsquo;re finding international tax issues arising for individuals and companies of all sizes. Many of them never thought they&rsquo;d have any cross-border activities. As many of our clients are CPA and law firm across the US, we thought it might be helpful to do a series of discussions on International Tax for the Non-Specialist. <u>They are <em>overviews</em> designed to assist practitioners identify issues.</u> The overview dive into some level of detail, but we envision separate sessions to more fully explain various technicalities.</p>

<p>This discussion is #3 in the series following: #1 on tax residency and foreign financial account disclosures [FBAR / FinCen 114 / Form 8938]. #2 on earning foreign income and an employee being transferred to a foreign affiliate).</p>

<p>The primary focus on this presentation is an overview of the US anti-deferral rules. This includes, but is not limited to:</p>

<ol>

<li>Discussion of international tax vs. domestic tax.</li>

<li>What is Subpart F?

<ol style=”list-style-type:lower-alpha;”>

<li>Where is it in the Code?</li>

<li>Who and how does it tax?</li>

<li>Why was it implemented?</li>

</ol>

</li>

<li>What is a US Shareholder?</li>

<li>What is a controlled foreign corporation (CFC) and examples to determine?</li>

<li>TCJA of 2017 changes.</li>

<li>What types of activities, income and investments does Subpart F reach?</li>

<li>Constructive ownership.</li>

</ol>

<p>&nbsp;</p>

<p>&nbsp;</p>

<p>Course Key Concept:<b> International tax, Subpart F, Controlled foreign corporation, CFC, Anti-deferral, Section 951, Section 957, Constructive, ownership, attribution, Deemed dividend, TCJA, US person, E&amp;P, Earnings and profits, Foreign base company income.</b></p>