This seminar will explain tax strategies for controlled foreign corporations (CFCs) and tax planning under subpart F income.  Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred. There are several exceptions to the categories of Subpart F income to reduce taxes.

This seminar is for corporate tax executives, law firm and accounting firm professionals who advise clients on structuring cross border transactions and on international tax planning matters. There is no advance preparation or prerequisites for this group live seminar. Field of Study: Taxes. Earn Up to 8 CPE/CLE Credits

Earn Up to 8 CPE/CLE Credits

Monday, May 1, 2017

8:30 AM Registration and Continental Breakfast

9:00 AM Overview of Subpart F Provisions - Basic Mechanics

  • Introduction
  • Controlled Foreign Corporations (Section 958)
  • Subpart F Income Definition and Exceptions (Section 952)
  • Investments in U.S. Property (Section 956)
  • Income Inclusion Requirements and Limitations (Section 951)
  • Calculating the Foreign Tax Credit (Sections 901, 902 and 960)
  • Previously Taxed Earnings (Section 959)
  • Sale of a CFC (Section 1248)
  • Affirmative Use of Subpart F

10:30 AM Refreshment Break

10:45 AM Section 954(d) – Foreign Base Company Sales Income

  • Foreign Personal Holding Company Income
  • Same-country Exception
  • Active Trade or Business Exception
  • CFC look-through - Section 954(c)(6)
  • Active Financing Income Exception
  • Foreign Base Company Services Income
  • Substantial assistance

12:15 PM Luncheon

1:00 PM Overview of Sections 954(c) and 954(e)

  • Foreign Personal Holding Company Income (FPHCI) defined in § 954(c)
  • Look-through Exception § 954(c)(6)
  • Notice 2007-9 – Anti-Abuse Rules
  • Foreign Base Company Services Income (FBCSI)
  • Substantial Assistance Test Notice 2007-13

2:15 PM Refreshment Break

2:30 PM Computing E&P and Section 1248

  • Calculation of E&P
  • Overview of Section 1248 and calculation of the Section 1248 amount
  • Foreign tax credit consequences of recognizing Section 1248 amount, interaction with Sections 338(g) and 338(h)(16)
  • Application of §367 to §304 Transactions
  • Final Section 1248 Regulations

4:00 PM Reporting Issues for Controlled Foreign Corporations and Disregarded Entities

  • Reporting Issues for Controlled Foreign Corporations (CFCs)
    • Accounting method changes affecting Earnings & Profits
    • Final GRA compliance regulations
    • Updates concerning IRS Form 5471
  • Recent developments in certain areas of the IRS code and regulations with regard to income tax compliance
    • Creditable foreign tax expenditures §1.704-1T
    • Foreign tax credit – credit vs. deduction

5:00 PM Seminar Concludes

Conference Location

Houstonian Hotel Club & Spa, 111 N Post Oak Ln, Houston, TX 77024Phone 713-680-2626