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

Join Adnan Islam, JD, MBA, LL.M., CPA, as he focuses on U.S. global informational reporting issues with a summary overview of select international tax provisions, post-TCJA. This on-demand course will not provide complex or computational examples of subpart F, GILTI or FDII.

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


Instructional Method

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

Registration Options
Regular Fee $55

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