Show navigation

Available in:

OnDemand Webinar
Audio & Reference Manual

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
Purchase Options

More Program Information

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

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

Purchase Options

More Program Information

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 Webinar

This course was last revised on February 20, 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

  • 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.

Purchase Options

More Program Information

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

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
Purchase Options

More Program Information

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.

All of your training, right here at Lorman.

Pay once and get a full year of unlimited training in any format, any time!

  • Live Webinars
  • OnDemand Webinars
  • MP3 Downloads
  • Course Manuals
  • Audio Recordings*
  • Executive Reports
  • White Papers and Articles
  • Sponsored Live Webinars

Additional benefits include:

  • State Specific Credit Tracker
  • Members Only Newsletter
  • All-Access Pass Course Concierge

* For audio recordings you only pay shipping

Questions? Call 877-296-2169 to speak with a real person.

Sign Up Today
With This Course

Access to all training products for one year
$699/year

Unlimited Lorman Training

With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!

Easy Registrations

Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.

Invest in Yourself

You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.

Product ID: 402178
Published 2018
Purchase Options

Available in Multiple Formats

Purchase this course and learn on your schedule!