International Tax Lunch: Guide to Global Intangible Low-Taxed Income (Section 951A)

Course Details

Date

Friday, January 10, 2020

10:00am – 11:00am
(Registration: 9:30am)

Field of Study

Taxation

Course Number

4193821A

CPE Credit

1 hour CPE credit

Level of Knowledge

Overview

Vendor

CalCPA Education Foundation

Prerequisites

None.

Description

U.S. shareholders of foreign corporations have a new pass-through income category to contend with: GILTI. Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders.

This session explores the new rules. What is GILTI? How will it affect U.S. shareholders? What countermeasures are available? 

Highlights

  • GILTI and new Section 951A.
  • Dividend received deductions.
  • Foreign tax credit.

Objectives

  • Understand what types of income will be characterized as GILTI.
  • Explore the interaction of GILTI's income recognition rules and the dividend received deduction rules.
  • Review the application of the foreign tax credit rules.
  • Examine different holding structures available to U.S. shareholders, and the effect of holding structure choice on the shareholders' tax liability. 

Designed For

Lawyers and CPAs.

Course Pricing

Member Fee

Applicable if you are a HSCPA member in good standing.

$30.00
Non-Member Fee

Applicable if you are not a HSCPA member.

$50.00
Your Price $50.00

CPE Choice

Learn more about CPE Choice.
This course does not qualify for CPE Choice.

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