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Section 951A - Global Intangible Low-Taxed Income (GILTI)

Gain an understanding of the overview of the Tax Cuts and Jobs Act of 2017 and the most recent changes that have occurred within Section 951A and GILTI. The Tax Cuts and Jobs Act of 2017 has completely changed the US taxation of income from foreign business operations of US companies. A significant change was the enactment of Section 951A and the GILTI provisions. Income that previously would not have been taxed under the Subpart F provisions of the Tax Code will now be immediately taxable in the US, despite the shift from a world-wide tax system to a territorial system. US companies will need to review the structure of their foreign business operations; much of the tax planning that was implemented before 2018 may need to be restructured so that those operations avoid the application of the GILTI provisions.


Runtime: 61 minutes
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Why Lorman?

Over 32 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 International Tax Law Changes in the Tax Cuts and Jobs Act of 2017

  • Territorial Tax System vs. World-Wide Tax System
  • Foreign Dividends Received Deduction
  • Taxation of Pre-2018 Accumulated Earnings

New Section 951A

  • New Category of Subpart F Income
  • Offshore Transfer of US Developed Intangibles
  • Computation of GILTI Inclusion
  • Computation of Business Asset Investment

GILTI Deduction; Foreign Tax Credits

  • Who Can Claim the Deduction?
  • Foreign Tax Credit Computations
  • Separate GILTI Basket Under Section 904
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Why Lorman?

Over 32 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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OnDemand Webinar

This course was last revised on April 24, 2018.

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

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

Audio & Reference Manual

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

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More Program Information

Why Lorman?

Over 32 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

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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Product ID: 402984
Published 2018
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