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Tax Treatment of Pre-2018 Accumulated Earnings

Gain an understanding of the new taxation processes that are taking place in the U.S. this year.The Tax Cuts and Jobs Act made significant changes to the U.S. taxation of foreign companies with U.S. shareholders. The switch from a world-wide approach to a territorial approach led to Congress enacting Section 965 which accelerated the U.S. tax on income of foreign companies accumulated before 2018 but not yet distributed. The new rules apply not just to controlled foreign corporations but to all foreign corporations with at least 1 U.S. shareholder. Under Section 965, not only must you decide whether to pay the tax in 2018 or to defer and pay the tax over an 8 year period, you also need to review the assets of each foreign company to determine whether that accumulated income will be taxed at an 8% effective rate or a 15.5% effective rate. There are beneficial provisions for U.S. shareholders who are S Corporations, and converting a C Corp to an S Corp before the effective date of the new legislation may be beneficial. Lastly, the acceleration of the inclusion of the pre-2018 accumulated earnings has significant implications for the treatment of that income for GAAP accounting purposes, particularly where the 'permanently reinvested' representation has been made.
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Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview of Prior U.S. Tax Treatment of Income From Foreign Subsidiaries
Overview of New Territorial Tax Treatment
Pre-2018 Accumulated Earnings
  • Deemed Subpart F Income Treatment
  • Deemed Distribution in 2017
  • Effective Tax Rate Calculations
Payment of Tax on Pre-2018 Accumulated Earnings
  • Tax Rates
  • Timing of Tax Payments
  • C Corp Shareholders
  • S Corp Shareholders
  • Individuals
Computing E&P/Forms 5471 Reporting
Determining E&P for Foreign Companies Which Are Not CFCs but Which Have U.S. Shareholders
GAAP Accounting Issues and the Permanently Reinvested Representation
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

Audio & Reference Manual

  • AK CLE 1.0
     
  • Arizona CLE 1.0
     
  • CA MCLE 1.0
     
  • CT CLE 1.0
     
  • GA CLE 1.0
     
  • HI CLE 1.0
     
  • IL CLE 1.0
     
  • ME CLE 1.0
     
  • MO CLE 1.2
     
  • MT CLE 1.0
     
  • NJ CLE 1.2
     
  • NM CLE 1.0
     
  • NV CLE 1.0
     
  • NY CLE 1.0 including Areas of Professional Practice 1
     
  • UT CLE 1.0
     
  • VT CLE 1.0
     
  • WA CLE 1.0
     
  • WV MCLE 1.2
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program format does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • AK CLE 1.0
     
  • Arizona CLE 1.0
     
  • CA MCLE 1.0
     
  • CT CLE 1.0
     
  • HI CLE 1.0
     
  • IL CLE 1.0
     
  • ME CLE 1.0
     
  • MO CLE 1.2
     
  • MT CLE 1.0
     
  • NJ CLE 1.2
     
  • NM CLE 1.0
     
  • NV CLE 1.0
     
  • NY CLE 1.0 including Areas of Professional Practice 1
     
  • UT CLE 1.0
     
  • VT CLE 1.0
     
  • WA CLE 1.0
     
  • WV MCLE 1.2
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program format does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Charles S. Kolstad

Charles S. Kolstad

Mitchell Silberberg & Knupp LLP

  • Tax partner in the Los Angeles office of Mitchell Silberberg & Knupp, LLP
  • Advises clients, accountants, and business managers throughout the U.S. on the income tax issues and reporting requirements that arise when individuals or companies conduct business outside of the U.S.
  • Advises U.S. clients on structuring foreign business activities with a view to minimizing their global effective tax rate on foreign income
  • Advised nonresident aliens planning on moving to the U.S. on the U.S. tax reporting requirements that apply once they become a U.S. tax resident, pre-immigration planning to step-up basis of assets, eliminate U.S. tax on previously earned income, etc.
  • Frequent speaker on income tax and international reporting requirements, and regularly prepares tax bulletins on topical issues
  • During his career, he has been a tax partner at both Coopers & Lybrand LLP and Ernst & Young LLP
  • J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University
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Product ID: 402178
Published 2018
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