Owners of foreign subsidiaries previously worried only about Subpart F income, but the 2017 Act created a new anti-deferral regime – Global Intangible Low-Taxed Income (“GILTI”). Very simply, GILTI forces the U.S. owner to report the income of the foreign subsidiary that is in excess of 10% of the foreign subsidiary’s depreciable assets. However, it is rarely that simple and the IRS has promulgated 80 pages of regulations (with a 70-page preamble) as guidance.
Who Should AttendTax practitioners in both public accounting and in industry engaging in planning or conducting compliance for foreign subsidiaries.
Instructional MethodGroup: Internet-based
NASBA Field of Study
Taxes (2 hours)