This CPE self-study course focuses on determining US shareholder and CFC status under the new rules from tax reform.
Learning Objectives
Identify a CFC and a U.S. shareholder;Apply constructive stock attribution rules properly (*Tax reform);Distinguish how rules around indirect and direct ownership is applied;Section 962 Elections;Differentiate the different types of subpart F income;Identify situations that would create subpart F income for a U.S. entity;Calculate subpart F income for specific scenarios;Apply specific rules providing exceptions and limitations for subpart F income;Identify the importance of E&P in an International Context;Recall E&P;Calculate Common E&P Adjustments;Apply E&P Concepts to common International Tax transactions;Determine when you have PFICs;Recognize the consequences of PFIC ownership;Differentiate the tax implications of PFIC elections;Recall PFIC reporting;Recognize Foreign Asset reporting requirements beyond PFIC
Major Topics
Determination of CFC and U.S. Shareholders;Application of constructive ownership rules;New downward attribution;Section 962;All forms of subpart F income (FPHCI, sales, and services);Operating rules;Exceptions;Why is E&P Important;Overview of the E&P Computation;Common E&P Adjustments;Applying E&P to Your Clients: What to look for and real-world examples;Reporting E&P on Form 5471;Tax issues resulting from E&P issues;Definition of a PFIC and Examples;Shareholder Taxation of PFICs without QEFs;Shareholder Taxation of PFICs with QEFs;Mark-to-market Elections (Mark-to-market 1296);Retroactive Relief;Foreign Asset Reporting Requirements;Excess Distribution 1291;Qualified Electing Funds 1293 & 1295;FBARs and 8938s
