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International Aspects of Tax Cuts and Jobs Act 2017 – Part III – Working and Planning with the New Participation Exemption (DRD) and Changes Foreign Tax Credit Regime and Previously Taxed Foreign Earnings and Profits

This program offers 1.5 participatory MCLE credits; 1.5 legal specialization in Taxation Law. You must register in advance to participate.

With deferral of U.S. income taxation of foreign earnings largely gone, a working knowledge of the new and changed mechanisms for elimination of double taxation is needed by tax practitioners.  In addition to covering the new participation exemption and the many changes to the foreign tax credit regime, the webinar will cover changes to the allocation of expenses under the expanded basket system for the determination of limits on the crediting of foreign income tax, treatment of withholding taxes and distributions of previously taxed foreign earnings, allocation of distributions from foreign corporation among the various categories of previously taxed income and other earnings and profits and the election by U.S. individuals of C corporation treatment for inclusion of foreign earnings under Subpart F and GILTI under Section 962.  These topics will be covered through a series of worked examples.

Speakers: Thomas Giordano-Lascari and William Norman

Moderator: Raul Villarreal Garza

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