Concurrent Session Onsite and Online

NTA2209. Today’s International Strategies: Opportunities and Traps

The Tax Cuts and Jobs Act (TCJA) ushered in massive changes for US based multinationals. Pass-through entities saw significant changes in the treatment of foreign income and activity which is giving rise to planning and compliance challenges. This session with take a practical look at international pass-through entities and the ramifications of the post TCJA regulatory changes. We will discuss the adoption of the aggregate theory for U.S. partnership owned CFC’s and the related tax considerations including tax basis adjustments, treatment of previously taxes income and the CFC/PFIC overlap rules. While additional guidance on several of these matters is almost certain in the future, taxpayers facing current planning and compliance challenges must navigate the complexity while managing risk without guidance in several key areas.


Learning Objectives:

  • Identify the tax related consideration of the TCJA on international pass-through entities
  • Determine how to minimize risk in key areas
Date/Time
–
CPE Credits
1.0
NASBA Field of Study
TAX
Level
Intermediate
Prerequisites
3-5 Years in the Profession
Advanced Preparation
None
Session Tags
Practitioners View
CFP
EA
National Tax
Speakers
Image of David Sites

David Sites

CPA
International Tax Partner
Grant Thornton
Image of Joseph Calianno

Joseph Calianno

CPA, J.D., MBA, LL.M. (Taxation)
Managing Director
Andersen Tax