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.