Covers the other major areas of US international tax reform such as DRD, GILTI, BEAT, FDII, and Section 965.
Learning Objectives
Identify new foreign dividends received deduction;Recall the new Global Intangible Low-Tax Income basket;Identify the Foreign Derived Intangible Income deduction;Recall the Base Erosion Anti-Abuse Tax;Identify the various types of Section 956 investments in U.S. property;Apply the exceptions to Section 956;Calculate Section 956;Apply Section 960(c);Identify when E&P becomes PTI;Determine the tax consequences upon a distribution of PTI;Identify the impact PTI has on outside tax basis in CFC stock;Determine when Section 1248 applies;How section 1248 is calculated.
Major Topics
GILTI;FDII;BEAT;DRD;Section 965;Section 956 – types;Calculation;960(c);Section 959 - PTI distributions and implications;Section 1248 applicability;Section 1248 calculations
