Tax Reform's Impact on International Business

  • Date/Time
    • May 18, 2018
    • Sign In: 10:30am (Mountain Time)
    • Program: 11:00am - 2:30pm (Mountain Time)
    • Add to Calendar
  • Location
    • Your Computer
  • Credits
    • 4.00
  • Credit Type(s)
    • Taxation (4.00)
  • Prerequisites
    • None

  • Vendor
    • Idaho Society of CPAs
  • Level
    • Update
  • Fields of Study
    • Taxation

Description

The monumental passing of the Tax Cuts and Jobs Act results in a significant impact to international business and the global economy. This CPE course provides a comprehensive overview of the changes and guidance on how businesses can identify opportunities and reduce their tax risks with international tax strategies.

Designed For

  • CPAs, tax professionals and other qualified professionals with basic knowledge of, and interest in, international tax
  • Management accountants and business team members involved in corporate tax function

Objectives

  • Identify changes impacting international tax provisions
  • Identify planning considerations for U.S. multinationals and foreign corporations doing business in the U.S.
  • Identify ways to advise clients on the impact of tax reform changes
  • Recognize new tax planning strategies post tax reform

Highlights

  • Overview of International Tax Reform
  • Overview of Business Provision (Non-international)
    • Rate Cut
    • Cost Recovery
    • Section 163(j)
    • Modification of NOL Rules
    • Carried Interest
    • Sale/Exchanges of Partnership Interests
  • The International Provisions
    • Quasi-Territorial
      • Dividends Received Deduction
      • Sales/Transfers of 10% owned foreign corporations
      • Foreign Branch Loss Transfer Recapture
      • Treatment of Deferred Foreign Income (One-Time Tax)
      • Example(s)
    • Rules Related to Passive and Mobile Income
      • GILTI/FDII
        • Global Intangible Low Taxed Income Inclusion (GILTI)
        • Deduction for Foreign Derived Intangible Income
      • Other Subpart F Modifications
        • Modification of Section 958(b)(4)
        • Modification of definition of U.S. Shareholder
        • Elimination of 30-Day control requirements
        • Other
      • Prevention of Base Erosion (outbound)
        • Section 936(h)(3)(B) changes
        • Hybrid Transaction Rules
        • No 1(h)(11) rate for "Inverted" companies
      • Modification Related to FTC System
        • Repeal of Section 902
        • Section 960 Determined in Annual Basis
        • Separate limitation basket for Foreign Branch Income
        • Source of Income from sales of Inventory
        • ODL Amendments
      • Inbound Transaction Rules
        • Base Erosion and Anti-Abuse Tax
        • Increase in Section 6038A Penalties
      • Other
        • Insurance Exception to PFCI Rules
        • Repeal of FMV Method of Interest Apportionment
  • Provisions impacting foreign income of U.S. persons/companies
  • Provisions impacting non-U.S. persons investing in the United States

Advanced Prep

  • Download PDF manual - view your upcoming events in "My CPE" on website
  • Test your computer/device for compatibility with virtual meeting space well in advance of your webinar

Registration Details

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