This webinar is presented at an intermediate level.  The webinar is designed for tax professionals working as outside international tax advisors and for tax and financial executives and staff employed by domestic corporations with current or future foreign operations. The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign sourced dividends paid to 10 percent US corporate shareholders from US federal income tax. The participation exemption applies to foreign sourced income that is not considered Subpart F, Global Intangible Low Taxed Income (GILTI) or income paid from a passive foreign investment company (collectively, the Foreign Corporation Regimes). Further, the participation exemption does not apply to “hybrid dividends,” which are dividends paid from a controlled foreign corporation (CFC) that received a deduction (or other tax benefit) with respect to any income, war profits, or excess profits taxes imposed by any foreign country or possession of the United States. If the participation exemption applies, the US corporate shareholder will not be entitled to claim foreign tax credits for any foreign tax imposed on the foreign sourced income.

Level: Intermediate
Delivery Method: Group-Internet Based Live
Recommended CPE/CLE Credit: 1.5 Credit
Field of Study: Taxes
Prerequisites:  An introductory course on international taxes and a working knowledge of international transactions
Advance Preparations: None
Who Should Attend: This webinar is for CPAs, tax executives, accountants, tax attorneys and financial executives

Presented By:

William K. Norman is a Partner in the law firm of Ord & Norman in Los Angeles, California and is a Coordinator of its Private Client and International Business Transactions Departments.  He is also a member of the firm’s Tax Litigation and Controversy Group.  He is a Certified Specialist in Taxation Law.  In his practice, he focuses on the counseling of clients in cross border business transactions, cross border real estate investment structures, personal wealth planning for the multinational family, offshore voluntary disclosures, expatriation's of U.S. citizens and green card holders, use of trusts by multinational families, and representation of taxpayers before the IRS and the Tax Court.  Mr. Norman received an A.B. degree in economics from the University of California at Berkeley, a J.D. degree from the University of California and an LL.M. (in taxation) degree from New York University School of Law.  He is a senior adjunct professor in the Graduate School of Taxation, Golden Gate University. He is immediate past chair of STEP-LA Branch.  He has appeared as a speaker and seminar leader at the USC Tax Institute and the New York University Tax Institute.  In June of 2008, the Taxation Section of the Los Angeles County Bar Association presented the Dana Latham Award to him in recognition of his outstanding contributions to the field of taxation. For more information: