Instructor for this course
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As a boutique international tax firm, we’re finding international tax issues arising for individuals and companies of all sizes. Many of them never thought they’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. They are overviews designed to assist practitioners identify issues. The overview dive into some level of detail, but we envision separate sessions to more fully explain various technicalities.

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).

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

  1. Discussion of international tax vs. domestic tax.
  2. What is Subpart F?
    1. Where is it in the Code?
    2. Who and how does it tax?
    3. Why was it implemented?
  3. What is a US Shareholder?
  4. What is a controlled foreign corporation (CFC) and examples to determine?
  5. TCJA of 2017 changes.
  6. What types of activities, income and investments does Subpart F reach?
  7. Constructive ownership.

 

 

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

Course Series

This course is included in the following series:

7 CoursesPractical International Tax for the Non-Specialist

  1. Practical International Tax for the Non-Specialist #1: Tax Residency and Foreign Financial Account Disclosures
  2. Practical International Tax for the Non-Specialist #2: Case Study - US Person Earning Foreign Income and then Transferred to Foreign Subsidiary.
  3. Practical International Tax for the Non-Specialist #3: Anti-deferral overview– Subpart F and CFCs.
  4. Practical International Tax for the Non-Specialist #4: US Taxation of Nonresident Individuals
  5. Practical International Tax for the Non-Specialist #5: Section 956, Investment of Earnings in US Property
  6. Practical International Tax for the Non-Specialist #6: Check The Box Overview (Entity Classification Election)
  7. Practical International Tax for the Non-Specialist #7: Foreign Investment in US Real Property - FIRPTA

Learning Objectives

  • Explore the anti-deferral rules.
  • Identify the policy behind the rules.
  • Discover the various ways a person may be a US shareholder and the potential impact.
  • Recognize when a company is a controlled foreign corporation and the impact on US shareholders.
Last updated/reviewed: May 5, 2020

Prerequisites

Course Complexity: Intermediate

No advanced preparation or prerequisites are required for this course. However it is recommended to take other Tax courses by Marc Schwartz: Practical International Tax for the Non-Specialist

Education Provider Information

Company:
Illumeo, Inc., 75 East Santa Clara St., Suite 1215, San Jose, CA 95113
Contact:
For more information regarding this course, including complaint and cancellation policies, please contact our offices at (408) 400- 3993 or send an e-mail to .
Course Syllabus
INTRODUCTION AND OVERVIEW
  5:06Introduction to Anti-deferral overview: Subpart F and CFCs.
  11:07Subpart F
  12:51Control Formed Corporation (CFC's)
  12:47Subpart F Do and Don't
  3:26Conclusion
CONTINUOUS PLAY
  45:17Practical International Tax for the Non-Specialist #3: Anti-deferral overview-Subpart F and CFCs.
SUPPORTING MATERIAL
  PDFSlides: Practical International Tax for the Non-Specialist #3: Anti-deferral overview-Subpart F and CFCs.
  PDFPractical International Tax for the Non-Specialist #3: Anti-deferral overview-Subpart F and CFCs Glossary/ Index
REVIEW AND TEST
  quizREVIEW QUESTIONS
 examFINAL EXAM