Surgent's U.S. Taxation of Foreign Corporations: A Case Study Approach

Overview

This course is a case study designed to provide a comprehensive overview of U.S. taxation of a foreign corporation. Using a specific example, the course will walk through step-by-step mechanics on how to calculate the income inclusions and foreign tax credits under GILTI (Global Intangible Low-Taxed Income), Subpart F, and PFIC (Passive Foreign Investment Company) regimes. The case study will further evaluate tax impact of subsequent distributions from the foreign corporation and sales of its stock. A compare-and-contrast approach will highlight the different outcomes of these regimes for individuals and for C corporations, empowering participants to advise their clients on the most tax efficient way to structure their international investments.

Highlights

Understand how to approach and analyze the U.S. taxation of foreign corporations
Using an example, calculate GILTI, Subpart F, and PFIC income inclusions for an individual and C corporation
Determine how much foreign tax credit can be claimed against such income inclusions
Determine how subsequent dividend distributions from the foreign corporation are taxed
Calculate capital gain on the disposition of the foreign corporation
Discuss the impact of Section 962 election
Compare different outcomes under GILTI, Subpart F, and PFIC regimes for individuals and corporations
Identify basic strategies for managing tax liabilities related to foreign corporations

Prerequisites

A basic understanding of the tax rules relating to individual and corporate income tax

Designed For

Any tax practitioner with clients invested in a foreign corporation

Objectives

Explain the similarities and differences between GILTI, Subpart F, and PFIC regimes
Understand the mechanics of income inclusions and foreign tax credits available under GILTI, Subpart F, and PFIC regimes
Compare and contrast the overall tax liability under different circumstances
Identify tax planning opportunities for income from foreign corporations