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Taxation of Foreign Income Provisions in the Tax Cuts and Jobs Act (TCJA)

Gain a better understanding of how the tax reform impacts taxation of foreign income.

As tax practitioners are beginning to digest the host of changes to the U.S. international tax laws enacted in late December and as guidance is being issued by the U.S. Treasury Department and the IRS regarding key technical issues, this topic will provide a brief overview of these new rules, but more importantly, will focus on various fact patterns in which these issues are raised. The panelists will provide insights on supply chain considerations for multi-national entities and to how to plan and structure from inbound and outbound perspectives in a post-tax reform world.

Runtime: 103 minutes
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Why Lorman?

Over 33 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

Changes to CFC Rules (Sections 951(a) and (b) and Section 958(b)(4))

Transition Tax (Section 965)

Gilti (Section 951A and Section 250)

FDII ( Section 250)

DRD (Section 245A)

Hybrid Provisions (Section 267A and Sections 245A(E))

BEAT (Section 59A)

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Why Lorman?

Over 33 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 Course

This course was last revised on May 10, 2018.

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

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

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Why Lorman?

Over 33 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

Kristin Konschnik

Butler Snow LLP

  • Attorney in the London office of Butler Snow
  • Practices in tax, taxation of businesses, tax exempt organizations and tax controversy
  • Advises individuals and their companies on U.S. and international transactional tax matters, including cross-border sales and acquisitions, intellectual property structuring, hedge and private equity funds, and tax-efficient U.S. inbound and outbound business and investments
  • Frequently works with founders, investors and management on a range of U.S. tax issues, including compensation matters, in private equity buyout and rollover transactions
  • Frequent speaker and has written numerous publications
  • J.D. degree, The University of Texas School of Law; B.A. degree, University of Virginia
  • Can be contacted at [email protected]

Brian S. Masterson

Butler Snow LLP

  • Member of Butler Snow’s Business Services Group
  • Concentrates practice on taxation law, corporate and partnership taxation, tax controversies, and joint ventures and strategic collaboration
  • Advises clients in all aspects of state and federal tax controversy matters from the initial contact by the taxing authority to litigation, if necessary
  • Draft and negotiate term sheets and letters of intent for acquisitions and joint ventures; operating agreements and partnership agreements; and stock purchase agreements and asset purchase agreements
  • Frequent speaker and has written numerous publications
  • LL.M. degree, taxation, Georgetown University; J.D. degree, with honors, University of North Carolina; B.S. degree, summa cum laude, Lipscomb University
  • Can be contacted at [email protected]
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Why Lorman?

Over 33 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.

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Product ID: 402202
Published 2018
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