Select International Tax Reporting Considerations Post-Tax Cuts & Jobs Act

Author: Adnan Islam

CPE Credit:  2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC

Learn to identify reporting obligations and general tax effects of select, new international tax provisions under the TCJA with this self-study course presented by Adnan Islam, JD, MBA, LL.M., CPA. This lesson is designed for International Tax Practitioners and Federal/Lead Tax professionals working with international business clients.

Publication Date: June 2019

Designed For
International Tax Practitioners & Federal/Lead Tax professionals working with international business clients.

Topics Covered

  • New and expanded Form 5471
  • Modified definition of a US Shareholder
  • Easier to have a Controlled Foreign Corporation (CFC)
  • Existing Subpart F income
  • GILTI tax - additional reporting: Form 8992 & Form 8993
  • Sections 956 and 245A coordination
  • Section 962 election for US individual Shareholders
  • Smith case
  • No FDII
  • Passive Foreign Investment Company (PFIC)
  • Annual reporting
  • Exposures & issues if no CFC
  • QEF election

Learning Objectives

  • Identify reporting obligations and general tax effects of select, new international tax provisions under the TCJA, including for a CFC, GILTI, and PFICs
  • Recognize how to mitigate GILTI tax with a Section 962 election for US individual shareholders
  • Recognize the adverse tax issues as a PFIC shareholder/owner
  • Differentiate schedule sections and how they apply to international tax reporting
  • Describe correct statements with respect to the new GILTI tax
  • Describe correct statements with regard to the Section 932 election
  • Identify advantages of inserting a C-Corp, with respect to GILTI for individuals
  • Recognize which form is used to compute the U.S. taxpayer's GILTI and FDII deduction
  • Describe which category is now used by U.S. shareholders of specified foreign corporations (SFCs) subject to the provisions of section 965, with respect to changes to Form 5471
  • Identify how separate Schedule E in Form 5471 has been expanded
  • Identify the purpose of Schedule P within Form 5471
  • Recognize which IRS form is used to calculate GILTI
  • Describe which type of entity is ineligible to make a Section 962 election
  • Identify the excess of an entity's deduction eligible income over its deemed tangible income return
  • Recognize which part of Form 8993 relates to the determination of deduction eligible income

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic knowledge and reading of subpart F income and CFCs (IRC Sections 951, 952, 954, 957, 958), IRC Section 962.

Advance Preparation
None

Registration Options
Quantity
Fees
Regular Fee $55.00

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