The Tax Cuts and Jobs Act of 2017 made certain changes to international tax rules that general practitioners should be aware of when advising clients with investments in foreign countries. This program is an intensive one-hour update for general tax practitioners who will be advising such clients.
- Provision allowing a U.S. corporate shareholder to receive a 100% dividend received deduction for dividends received from a foreign corporation
- Requirement that taxpayers recognize as subpart F income all undistributed earnings of a foreign corporation
- Requirement that a U.S. shareholder of any CFC include Global Intangible Low-Taxed Income (GILTI) in the shareholder’s gross income during the current year
- Repeal of Section 958(b)(4) resulting in the attribution of a foreign corporation’s ownership in an affiliated foreign corporation to a U.S. shareholder
- Help advise clients with investments in foreign countries regarding the new tax rules that result from the Tax Cuts and Jobs Act of 2017
Tax practitioners who anticipate advising clients with investments in or doing business in foreign countries or who have investments in businesses that do
A basic understanding of the tax rules relating to individual income tax