Description
This CPE self-study course focuses on determining US shareholder and CFC status under the new rules from tax reform.
Objectives
- Identify a CFC and a U.S. shareholder
- Apply constructive stock attribution rules properly (
- Tax reform)
- Distinguish how rules around indirect and direct ownership is applied
- Section 962 Elections
- Differentiate the different types of subpart F income
- Identify situations that would create subpart F income for a U.S. entity
- Calculate subpart F income for specific scenarios
- Apply specific rules providing exceptions and limitations for subpart F income
- Identify the importance of E&P in an International Context
- Recall E&P
- Calculate Common E&P Adjustments
- Apply E&P Concepts to common International Tax transactions
- Determine when you have PFICs
- Recognize the consequences of PFIC ownership
- Differentiate the tax implications of PFIC elections
- Recall PFIC reporting
- Recognize Foreign Asset reporting requirements beyond PFIC
Highlights
- Determination of CFC and U.S. Shareholders
- Application of constructive ownership rules
- New downward attribution
- Section 962
- All forms of subpart F income (FPHCI, sales, and services)
- Operating rules
- Exceptions
- Why is E&P Important
- Overview of the E&P Computation
- Common E&P Adjustments
- Applying E&P to Your Clients: What to look for and real-world examples
- Reporting E&P on Form 5471
- Tax issues resulting from E&P issues
- Definition of a PFIC and Examples
- Shareholder Taxation of PFICs without QEFs
- Shareholder Taxation of PFICs with QEFs
- Mark-to-market Elections (Mark-to-market 1296)
- Retroactive Relief
- Foreign Asset Reporting Requirements
- Excess Distribution 1291
- Qualified Electing Funds 1293 & 1295
- FBARs and 8938s