It’s all about earnings and profits.
When computing accumulated earnings and profits, Section 965 applies only to post-1986 earnings and profits. Section 965 includes all post?1986 E&P other than E&P attributable to the income which is effectively connected with a U.S. trade or business and E&P which would be excluded from income under Section 959. To the extent provided for in regulations, post?1986 earnings and profit of a specified foreign corporation which has shareholders who are not U.S. shareholders will be treated as previously taxed income to the extent of their allocable share. This video reviews how Form 5471 will be revised to reflect the changes to E&P reporting resulting from the enactment of new Section 965.
Charles S. Kolstad
Withers Bergman LLP
- Tax partner Withers Bergman LLP, a leading international private capital law firm, specializing in international tax matters
- Focuses his practice on international tax, corporate, and partnership matters; he assists clients in tax and corporate planning relating to the acquisition, disposition and restructuring of businesses, corporations and partnerships both domestically and internationally
- Frequently advises foreign individuals moving to the U.S. on pre-immigration, income, gift and estate tax planning opportunities; he also focuses his practice on the cannabis industry/cannabusiness, crypto assets and block chain technology, and tax issues related to initial coin offerings (ICOs)
- Has advised over 200 clients with unreported foreign 1nancial accounts, foreign trusts, and other foreign investments, on the 1ling of FBARs and other information returns, and whether participating in the IRS’s various offshore voluntary disclosure programs is appropriate
- Written and lectured on the extensive information reporting requirements for U.S. taxpayers with international business operations
- During his career he’s been at Mitchell Silberberg & Knupp LLP and Venable LLP and was a tax partner at both Coopers & Lybrand and Ernst & Young
- J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University
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