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.
Publication Date: November 2020
Designed For
Experienced international tax staff through international tax director level interested in or already practicing international taxation.
Topics Covered
- Section 951 Overview
- What is GILTI?
- GILTI high tax exception regulations summary and highlights
- GILTI High”Tax Exclusion: Computational Steps
- Practical considerations for applying the GILTI high tax exception
- Subpart F Income High Tax Exception July 2020 Proposed Regulations
- Common Questions
Learning Objectives
- 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.
- Identify the GILTI Pro Rata Inclusion calculation
- Identify the GILTI High”Tax Exclusion Computational Steps
- Identify the GILTI High-Tax Exclusion steps
Level
Overview
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
Instructor
Adnan Islam
Adnan Islam, Esq., CPA, is a partner with Friedman LLP, co-chair of the International Tax Services group, and a leader of its Blockchain/Digital Asset Transactions group. He has nearly 17 years of public accounting experience as a licensed tax attorney and CPA. Adnan has served an array of industries and clients ranging from startups to publicly traded companies including Avon, MeadWestVaco, Honeywell, Verizon, Agilent, SunGard, Booz Allen, IDT, SunGard, AMEX, OUAI, IBISWorld, Conair, Grayscale, DCG, and various blockchain and crypto (digital asset) companies, exchanges, and private equity and hedge funds. Adnan specializes in cross-border strategies, comprehensive inbound tax services, global information reporting, and structuring for crypto funds, companies, and exchanges.
As an industry thought leader, Adnan has lectured on international tax at TEI events, AICPA seminars and served as an adjunct professor for Golden Gate University Master’s in Tax curriculum. Adnan’s expertise includes advising clients at all stages of business and restructuring, with respect to FDII, GILTI, 245A DRD, subpart F, PFICs, and other issues. Additionally, Adnan empowers his clients’ decision-making and improves their supply chain and operational efficiency, including the use of holding companies, treaty country networks, and affirmative tax planning through comparative rate modeling.
Adnan is a licensed attorney admitted to practice law in New Jersey, DC, and California and a Certified Public Accountant (NY & CA). He holds a Juris Doctor (J.D.) and an M.B.A. from Rutgers University; an LL.M. in Taxation from the New York University School of Law; a blockchain business certificate from MIT; and is currently enrolled in Georgetown Law's Tax LL.M. (International Tax Certificate) program. Adnan has been admitted as a Certified Legal Specialist in Tax Law by the State Bar of California. He also is an (inactive) enrolled agent (through IRS exam).