Select International Tax Reporting Considerations Post-Tax Cuts & Jobs Act (Currently Unavailable)

Author: Adnan Islam

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