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

Course Details


Friday, January 10, 2020

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

Field of Study


Course Number


CPE Credit

1 hour CPE credit

Level of Knowledge



CalCPA Education Foundation




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? 


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


  • 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.

Registration for this course has passed.

Course Pricing

Member Fee

Applicable if you are a HSCPA member in good standing.

Non-Member Fee

Applicable if you are not a HSCPA member.

Your Price $50.00

CPE Choice

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

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