Tax Planning for CFCs Under Subpart F Income

SubF NYC copy.jpg
SubF NYC copy.jpg

Tax Planning for CFCs Under Subpart F Income


December 11, 2017 - Regis, 1501 Broadway, New York, NY

Earn Up to 8 CPE/CLE Credits

Early Registration valid until Nov. 11, 2017. Price will increase $200 after Nov. 11th. Please see our Terms & Conditions for our Financial Aid, Cancellation, Administrative and Other Policies

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This basic level 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.  (We need to apply for NYS MCLE for this Course)
Earn Up to 8 CPE/CLE Credits

Monday, December 11, 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

Lucas Giardelli, Associate, Mayer Brown LLP, New York, NY

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

John C. Crucs, Managing Director, KPMG LLP, Short Hills, NJ

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

Trevor Blumenfeld, Tax Manager, KPMG LLP, New York, NY

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

Karen N. Ganesh, Senior Manager, Ernst & Young LLP, New York, NY
Chi Fung Yee, Senior Manager, Ernst & Young LLP, New York, NY

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

Regus Meeting Room, 1501 Broadway, 12th Floor, Manhattan, New York, 10036-5601, United States. Phone: 1 646 571 2000

For Hotel Reservations please call us at 877-500-1510.  We have a block of rooms at the Crowne Plaza - Times Square.

Speaker Biographies

Trevor Blumenfeld is a Tax Manager in KPMG’s International Tax Group, where he provides services to U.S and foreign, multi-national companies in regards to U.S. international taxation issues.  Such issues often involve U.S. tax deferral (e.g., subpart F income calculations), cash repatriation planning, cross border mergers and acquisitions, foreign currency exchange calculations, tax treaty analysis and U.S. international tax filing obligations.  Trevor joined KPMG in 2011.  Prior to that, he practiced as an auditor for another accounting firm.  Trevor earned his JD at St. John’s University School of Law School and his LLM in Taxation from New York University.

John Crucs is a senior manager in the international corporate services group at KPMG LLP where he provides tax consulting services to a broad range of multinational clients.  He has over fourteen years of tax experience based out of Boston, New York, and New Jersey.  His practice involves advising clients on structuring and managing their global operations to reduce their worldwide effective tax rates.  In addition to global tax planning, John has experience with other tax matters including preparing and auditing U.S. corporate tax provisions, preparing and reviewing U.S. corporate international tax compliance, and responding to audit inquiries by U.S. and foreign taxing authorities.  Prior to joining KPMG, John was a tax director at the global luxury goods company LVMH, where he was responsible for U.S. tax planning and operations. Prior to that, he served as a senior tax manager at Deloitte and a senior associate at Andersen.  John received his B.A. from The College of the Holy Cross in 1995 and his J.D. from Boston College Law School in 1998.  He is a member of the tax section of the New York Bar Association. John earned his JD from Boston College Law School; his BA from The College of the Holy Cross and is a member of the New York Bar Association, Tax Section.

Karen N. Ganesh is an experienced senior manager in the International Tax quantitative Service practice.  Karen is based in New York and has been with Ernst & Young LLP for over 10 years.  Her experience within international tax consists of tax compliance including Form 5471, 8865, 8858, and 8621, Subpart F analysis, Earnings & Profit studies, Foreign Tax Credit, tax reporting/disclosure for cross-border transactions under IRC Sec. 301, 302, 304, 332, 351, 367 etc., tax basis balance sheets, ASC 740, and FIN 48 analysis. Karen primary works with large private equity and media and entertainment clients. She graduated from Baruch College with BBA in Accountancy and MBA in Finance and Taxation.

Lucas Giardelli is an associate in the Tax Transactions & Consulting practice at Mayer Brown in New York. Lucas concentrates his practice on international tax planning and corporate tax matters, advising clients on the tax aspects of cross-border restructurings, mergers, acquisitions, financing arrangements and other transactions.  Prior to joining Mayer Brown, Lucas practiced Tax law at a leading law firm in Argentina.  Lucas earned an LLM from Harvard Law School and an LLM in Tax Law from Austral University (Argentina), where he also obtained his Law Degree (Gold Medal).  Lucas is admitted to practice in New York and Argentina.

Chi Fung Yee is a member of the International Tax Services practice of Ernst & Young LLP based in New York, NY.  He has over ten years of international tax experience. In his current role he provides services to US multinationals on all aspects of US international taxation including planning and tax compliance. Chi received his BBA in Accountancy and Master’s degree in Taxation from Baruch College.