Taxation

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. Read more

TCAJA introduced two alternative tax regimes available to U.S. based businesses serving foreign markets.  The two regimes are the Foreign Derived Intangible Income (FDII) available only to domestic C corporations and Qualified Business Income (QBI) Deduction (§199A).  FDII offered a 13.125% effective corporate tax for C corporations.  QBI offers an effective rate of 29.6% to individuals and noncorporate owners of passthrough business entities.  These two essentially alternative and mutually exclusive concepts need to be considered by practitioners advising clients with foreign customers.  Both provisions with emphasis on FDII will be illustrated with worked examples reflecting the latest available guidance. Read more

In many cases GILTI eliminates meaningful opportunities for deferral of U.S. Federal income tax on foreign earnings of U.S. owned foreign corporation and essentially imposes a 10.5% minimum tax.Under final regulations issued in June 2019, complex issues of computing the current inclusion, return of qualified business asset investment, high tax exception for Subpart F income and related foreign tax credit issues are addressed.  The webinar will cover the more significant provisions of the regulations with worked examples and planning suggestions. Read more

CLA Taxation Section members get the member rate with the promocode CLA 2.0 MCLE Credit; 2.0 CPE Credit Tuesday, July 23, 2019, 12 noon - 2 p.m. This Webinar timely reviews the finalized centralized partnership audit regime regulations promulgated by the IRS in final form on February 27, 2019. Understand how the new regime will be implemented in conjunction with previously-promulgated rules allowing for an election out of the regime. Learn how to identify critical operational provisions and effectively navigate… Read more

This program offers 1.25 participatory MCLE credits; 1.25 Legal Specialization in Taxation Law. You must register in advance to participate. Foreign investors continue to invest heavily in U.S. real estate. For U.S. income and transfer tax purposes, foreign investors and their advisers must weigh a number of tax issues to determine the appropriate structure for the ownership of U.S. real property, such as direct ownership or use of a foreign or domestic corporation, partnership, LLC and/or trust, in order to… Read more

The 2019 Annual Income Tax Seminar. Earn 7.5 Hours MCLE Credit. Includes Legal Ethics. Friday, June 28, 2019. Catamaran Resort Hotel and Spa 3999 Mission Boulevard San Diego, CA 92109 Read more

Education, Professional Development, Reinforcement of Your Inspired Idea to Become a Tax Lawyer. Monday, May 13, 2019 Golden Gate University 536 Mission St. San Francisco, CA 94105 Read more

Make plans to join us for California’s foremost tax conference, the 2019 Annual Meeting of the California Tax Bar and California Tax Policy Conference! Satisfy your annual MCLE requirements in beautiful sunny San Diego while networking with key tax officials, fellow tax practitioners, colleagues and friends. Read more

The 2019 Annual Income Tax Seminar is on Friday, June 28, 2019 at Catamaran Resort Hotel and Spa. This program is co-sponsored by CalCPA. Earn 9 hours CPE for CPAs; 9 hours continuing education for enrolled agents. Learn more about our program and we hope to see you there. Read more

The 6th Annual Young Tax Lawyers Conference is on Monday, May 13, 2019 at Golden Gate University. Earn 3 hours of MCLE Credit, including Legal Specialization and 1 Hour of Legal Ethics. Read more