August 08, 2018 - EST

"International Aspects of Tax Cuts and Jobs Act2017 Section 965 Technical Workshop" for STEP LA

This event has already occurred.

STEP LA presents a second practical workshop in its series on the major international aspects of the Tax Cuts and Jobs Act 2017. This workshop is being held just a few weeks before the filing deadline for individuals and corporations reporting on the calendar year. A panel of experienced practitioners will review the major issues in applying convoluted mechanics of the transition tax imposed under Section 965 on "US Shareholders" with respect to accumulated post 1986 E & P of "deferred foreign income corporations." This workshop will also address the proposed regulations under Section 965 that were released on August 1, 2018. In this interaction workshop, a panel discussion will begin with a worked example using worksheets in IRS Pub. 5292. The panel will thereafter pay particular attention to the following topics, time permitting:

  • Dealing with late installment payments and qualifying for relief from estimated tax penalties.
  • Impact of repeal of the restriction on the downward attribution rule.
  • Relief from the double counting and other anomalies addressed in recent IRS guidance.
  • Determining whether to make a corporate tax rate election for individuals under Section 962.
  • Working with fiscal year foreign corporation and U.S. shareholders under Section 965.
  • Definitional ambiguities in key Section 965 terms.
  • Foreign tax credit determination under the new ordering (stacking) rules for previously taxed income under Section 959.

Register for this program.