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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.

Runtime: 60 minutes
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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

OnDemand Webinar

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on February 20, 2018.

Call 1-866-352-9540 for further credit information.

  • AK CLE 1.0
     
  • Alaska attorneys may receive 1.0 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
     
  • AL CLE 1.0
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.0 hours credit.
     
  • Arizona CLE 1.0
     
  • The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.0 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.0
     
  • Lorman Business Center, Inc. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.0 CLE hours of participatory credit.
     
  • CO CLE 1.0
     
  • This program may qualify for 1.0 credit hours through the Colorado Supreme Court Board of Continuing Legal and Judicial Education through reciprocity. This course is accredited in other jurisdictions such as New Jersey. To receive CLE credit for this program, a home study affidavit must be submitted to the Supreme Court Board of Continuing Legal and Judicial Education.
     
  • CT CLE 1.0
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.0 CLE credit(s).
     
  • GA CLE 1.0
     
  • This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.0 CLE hours.
     
  • HI CLE 1.0
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.0 CLE credit hours.
     
  • IL CLE 1.0
     
  • This course was approved for a total of 1.0 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.0
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.0 hours of CLE credit under M. Bar R. 12.
     
  • MO CLE 1.2
     
  • This course qualifies for self-study CLE credit in Missouri.
     
  • MS CLE 1.0
     
  • This program has been approved by the Mississippi Commission on Continuing Legal Education for a maximum of 1.0 credit hours.
     
  • MT CLE 1.0
     
  • This program has been approved by the Montana Commission of Continuing Legal Education for a total of 1.0 CLE credits.
     
  • ND CLE 1.0
     
  • North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.0 hours of CLE credit.
     
  • NH MCLE 1.0
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 60 Minutes.
     
  • NJ CLE 1.2
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.2 hours of total CLE credit.
     
  • NM CLE 1.0
     
  • This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.0 hours of credit.
     
  • NV CLE 1.0
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.0 CLE hours.
     
  • NY CLE 1.0 including Areas of Professional Practice 1
     
  • This course has been approved in accordance with the requirements of the New York Continuing Legal Education Board for up to a maximum of 1.0 credit hours in the area(s) of Areas of Professional Practice for 1.00 hour. Each hour may be counted only as satisfying one category of credit. Duplicate credit for the same hour of instruction is not permitted. This course qualifies for both established and newly admitted attorneys. Lorman Business Center, Inc. has a financial hardship guideline. Please contact customer service at 1.866.352.9539 for instructions on how to apply.
     
  • PA CLE 1.0
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.0 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.0
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.0 hours of CLE credit.
     
  • TN CLE 1.0
     
  • This program has been approved as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.0 hours of credit.
     
  • UT CLE 1.0
     
  • This program has been approved by the Utah State Board of Continuing Legal Education for 1.0 CLE hours.
     
  • VT CLE 1.0
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.0 hours of self-study CLE credit.
     
  • WA CLE 1.0
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.0 hours of A/V credit under the Law & Legal Procedure category.
     
  • WI CLE 1.0
     
  • This program has been approved by the Board of Bar Examiners for 1.0 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 1.2
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.2 MCLE hours.
     
The CLE Code is ONLY a requirement when applying for CLE Credit in New York. Other states do not need to supply the CLE Code to apply for CLE credit.

To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.

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

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 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 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 accountants, business managers and clients throughout the US on the income tax issues and reporting requirements that arise when individuals or companies conduct business outside of the US
  • Assist clients with the offshore migration of US developed Intellectual Property
  • Advises nonresident aliens planning on moving to the US on the US tax reporting requirements that apply once they become a US tax resident, pre-immigration planning to step-up basis of assets, eliminate US tax on previously earned income, etc.
  • Represented some 160 clients with unreported foreign bank accounts, foreign trusts, 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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Why Lorman?

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Product ID: 402178
Published 2018
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