New Section 951A: Global Intangible Low Taxed Income (GILTI)
Thursday, November 1, 2018 - Earn 1.5 CPE/CLE Credits
Live Webinar United States Time Zones:
1:00 p.m. – 2:30 p.m. EDT / 12:00 p.m. – 1:30 p.m. CDT / 11:00 a.m. – 12:30 a.m. MDT / 10:00 a.m. – 11:30 a.m. PD30
The Tax Reform Act provides new Code Section 951A, which requires each U.S. Shareholder of a controlled foreign corporation (“CFC”) to currently include in its income its global intangible low-taxed income (“GILTI”) in the applicable tax year. GILTI is the excess of the U.S. Shareholder’s “net tested income” over its “net deemed tangible income return.” Such residual amount is deemed intangible income subject to tax. A U.S. Shareholder that includes GILTI in its income is allowed to increase its basis in the CFC stock and such GILTI amounts are treated as “previously taxed income” for subpart F purposes. In addition, new Code Section 250 provides a deduction that reduces effective tax rates on GILTI for U.S. Shareholders of eligible C corporations.
These new rules are effective for tax years of CFCs beginning after December 31, 2017, and for tax years of U.S. Shareholders in which or with which such tax years of the CFC ends. According to the Joint Committee on Taxation, the GILTI regime will increase revenues by $112.4 billion over 10 years.
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.
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.
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: