Section 951A (GILTI) Final High Tax Exception 2020 Regulations (Completed)
Date: Tuesday, November 3, 2020
Instructor: Adnan Islam
||12:00pm Pacific Time
1:00pm Mountain Time
2:00pm Central Time
3:00pm Eastern Time
||2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC
This course will cover the GILTI high tax exception (2020) regulations, planning issues, and effective tax rate considerations in applying these final regulations. This course will also provide a high level summary of the fundamental GILTI computational rules and corresponding, annual reporting requirements for U.S. Shareholders of CFCs with tested income. GILTI was enacted as new Section 951A under the Tax Cuts and Jobs Act (TCJA), along with subsequent proposed, final (2019 and 2020), and coordinating regulations. Note that both the GILTI and FDII deductions are defined within Section 250.
Who Should Attend
Experienced international tax staff through international tax director level interested in or already practicing international taxation.
- What is GILTI?
- GILTI high tax exception regulations summary and highlights
- Practical considerations for applying the GILTI high tax exception
- Identify the GILTI high tax exception under Treas. Reg. 1.951A-2
- Recognize the basic differences between GILTI and subpart F income
- Recognize practical considerations and potential issues that may negatively impact a taxpayer's effective tax rate when assessing the GILTI high tax exception.
NASBA Field of Study
Taxes (2 hours)