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Tax treaties between the United States and other countries cover a variety of topics, including income. The treaties create a parallel Federal tax law to the Internal Revenue Code, and sometimes it is useful to opt out of the Code and into the treaties for tax planning purposes. In this presentation, we will focus on individual taxpayers: when are tax treaty elections permitted, how you make an election, and how you decide whether making a treaty election is a good idea.
Presenter: Phil Hodgen
Materials: Drop box
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The new international tax rules now make most foreign corporation income immediately taxable to U.S. shareholders (via the Subpart F and GILTI rules). Section 962 gives individual taxpayers an election to be taxed on Subpart F income and GILTI at corporate tax rates (21%) rather than individual tax rates (as high as 37%). Should individual shareholders make this election? (Hint: the election’s consequences are not all rainbows and unicorns.)
Presenter: Phil Hodgen
Materials: Dropbox
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U.S. shareholders of foreign corporations have a new pass-through income category to contend with: GILTI. Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders. This session explores the new rules. What is GILTI? How will it affect U.S. shareholders? What countermeasures are available?
Presenter: Phil Hodgen
Materials: Dropbox
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American entrepreneurs abroad face brutally complex U.S. international tax rules. These rules add complexity, tax liability, and expense to the entrepreneur’s life. This session will walk you through all of the major holding structures choices available to an American entrepreneur abroad. We will explore the expected U.S. tax cost as well as the paperwork load for each structure.
Presenter: Phil Hodgen
Materials: Dropbox
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U.S. shareholders of foreign corporations must file Form 5471. But how do you know how much stock you own, and indeed if you are even an “owner”? The constructive ownership rules and attribution rules for Form 5471 are complicated, and getting this wrong might mean that you miss a filing requirement. Learn which rules to apply for different categories of Form 5471 filing requirements. Learn how to apply IRC §§318, 6038, and 6046 to find your answers.
Presenter: Phil Hodgen
Materials: Dropbox
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