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.

Major Topics

• 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

Learning Objectives

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

Designed for

Any tax practitioner with clients invested in a foreign corporation

CPE Credit

You will earn 3 CPE credits for attending.

About the Speaker

Renata Stasaityte, CPA is a Senior Manager with Martin DeCruze in Stamford, CT. Renata has over fifteen years of broad professional experience in a variety of areas. Her focus is business and international tax, ranging from getting technology start-ups off the ground to tax planning for complex international transactions. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She has worked extensively in the area of U.S. international tax reporting, including FBAR and Forms 5471, 8865, 8858, 8621, 5472, 1042.