Subpart F: - Subpart F Income and Categories - Earnings and Profits - Certain CFC Deficits - Information Reporting - High Tax Exception GILTI: - Net CFC Tested Income/Tested Losses - Deemed Tangible Income Return - CFC Groups - Information Reporting - High Tax Exception
Learning Objectives
- Upon completion of this course, you'll be able to:
- Define Subpart F income categories and GILTI components (e.g., tested income, deemed tangible return) and explain their tax treatment under current IRS rules.
- Calculate hypothetical Subpart F income inclusions and GILTI amounts, incorporating earnings and profits (E&P), CFC deficits, and high-tax exceptions.
- Develop a compliance checklist for CFC reporting, addressing information reporting requirements and elections (e.g., high-tax exception, grouping rules) to optimize global tax outcomes.
Major Topics
- Subpart F:
- Subpart F Income and Categories
- Earnings and Profits
- Certain CFC Deficits
- Information Reporting
- High Tax Exception GILTI:
- Net CFC Tested Income/Tested Losses
- Deemed Tangible Income Return
- CFC Groups
- Information Reporting
- High Tax Exception
