GILTI and FDII: Structuring Multinational Businesses

This course provides a detailed review of United States tax considerations for American taxpayers engaged in foreign business activities.

This course covers the following Topics:
>> Learn how foreign entities are classified for U.S. tax purposes
>> Learn how to determine whether a foreign corporation is a controlled foreign corporation subject to GILTI/Subpart F rules
>> Understand how GILTI and Subpart F provisions create current inclusions for U.S. shareholder
>> Recognize the potential benefits of U.S. incorporation for foreign activities based on the FDII deduction
>> Understand how to determine the best option for structuring foreign activities