International Tax Lunch: Guide to Global Intangible Low-Taxed Income (Section 951A)
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.
Lawyers and CPAs.
Applicable if you are a HSCPA member in good standing.
Applicable if you are not a HSCPA member.