U.S. Taxation of Foreign Corporations: A Case Study Approach
-
Virtual
3.00 Credits
Member Price $139.00
Non-Member Price $189.00
Overview
You could pay $0 for this course!
This course qualifies for EA/IRS and CFP credit. If you need EA/IRS credit, please contact Tyler Dion (tdion@masscpas.org) after you have registered and provide him your PTIN number.
This course is a case study designed to provide a comprehensive overview of U.S. taxation of a foreign corporation. Using a specific example, the course will walk through step-by-step mechanics on how to calculate the income inclusions and foreign tax credits under GILTI (Global Intangible Low-Taxed Income), Subpart F, and PFIC (Passive Foreign Investment Company) regimes. The case study will further evaluate tax impact of subsequent distributions from the foreign corporation and sales of its stock. A compare-and-contrast approach will highlight the different outcomes of these regimes for individuals and for C corporations, empowering participants to advise their clients on the most tax efficient way to structure their international investments.This course qualifies for reimbursement through the state’s Workforce Training Express Fund. Firms/companies with fewer than 50 staff can be reimbursed up to 100% of the cost of training and firms/companies with 50-100 employees can be reimbursed up to 50% of the cost of training. You must register for the course and apply for reimbursement through the Workforce Training Express Fund website a minimum of three weeks prior to the start of the course. The course code for this program is C-13062. To learn more, click here or contact Julia Ekelund at jekelund@masscpas.org.
Highlights
Understand how to approach and analyze the U.S. taxation of foreign corporations Using an example, calculate GILTI, Subpart F, and PFIC income inclusions for an individual and C corporation Determine how much foreign tax credit can be claimed against such income inclusions Determine how subsequent dividend distributions from the foreign corporation are taxed Calculate capital gain on the disposition of the foreign corporation Discuss the impact of Section 962 election Compare different outcomes under GILTI, Subpart F, and PFIC regimes for individuals and corporations Identify basic strategies for managing tax liabilities related to foreign corporations
Prerequisites
A basic understanding of the tax rules relating to individual and corporate income tax
Designed For
Any tax practitioner with clients invested in a foreign corporation
Objectives
Explain the similarities and differences between GILTI, Subpart F, and PFIC regimes Understand the mechanics of income inclusions and foreign tax credits available under GILTI, Subpart F, and PFIC regimes Compare and contrast the overall tax liability under different circumstances Identify tax planning opportunities for income from foreign corporations
Preparation
None
Leader(s):
Leader Bios
Pamela Davis-Vaughn, Surgent McCoy CPE LLC
Pamela J. Davis-Vaughn is a general practitioner providing accounting, tax, and consulting services to clients across the United States from her office in Painted Post, New York. She has designed and taught undergraduate and graduate courses in state and local tax at Texas universities, including Baylor and Texas Tech, and has been a highly rated speaker at the Controller’s Roundtable, a sponsored event for controllers of automobile dealerships in Texas. In addition to her accounting practice, Pam and her husband, Darryl, are owners of One Main Place Farms, an organic farming operation located in upstate New York. Pam has over 25 years of experience in both public and private accounting sectors. Her public experience ranges from a Big Four firm where she assisted several Fortune 500 companies in restructuring their operations to provide state income and franchise tax savings, participated on the mergers and acquisitions team, and served as the Southwest Area Employment Tax practice leader to providing tax consulting services for closely held businesses of a 16-partner, 100-staff Dallas CPA firm. Her experience in the private sector as CFO of a Dallas based manufacturer servicing the telecom industry and Tax and Accounting Manager of a large independent oil and gas company provides her with significant insight into the challenges faced by those practicing in industry. Pam holds a BS degree in Business and Accounting from the University of Kansas, an MBA from Wichita State University, and has completed post-graduate work in International Tax at New York University. She holds a license to practice in Kansas, Texas, and New York.
Non-Member Price $189.00
Member Price $139.00