2019 International Tax Provisions Recap & Update (Completed)

Join Adnan Islam, JD, MBA, LL.M., CPA, for a a high-level overview of international tax developments. This course will take a closer look into 2018 & 2019 international tax guidance, including recent regulations and notices within this area. The course will also focus on GILTI and FDII.

Who Should Attend
International Tax Practitioners & Federal/Lead Tax professionals working with international business clients.

Topics Covered

• Section 951A GILTI proposed regulations recap
• Substantive GILTI proposed regulations
• Computational and coordination rules for GILTI
• Consideration points on conducting international business operations, through US C corp, a CFC, a foreign corp (non-CFC), or foreign branch
• Section 250 FDII
• New substantive FDII proposed regulations
• New procedural regulations and documentation requirements for FDII incentive effective tax rate
• Comparing FDII with the existing IC-DISC export regime

Learning Objectives

• Identify the general impacts of select outbound US international tax provisions, such as GILTI and FDII
• Identify primary and effective provisions of GILTI and FDII, and the respective US informational and tax liability reporting
• Recognize what to consider use of the C corp, CFC, or both forms of business

Level
Update

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic knowledge of subpart F income (IRC Sections 951, 952 and 954), IRC Sections 951A, and 250.

Advance Preparation
None