Wolters Kluwer's Global Intangible Low-Taxed Income and Form 8992

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May 20, 2021

Instructor: William J. Seeger

Special BKR Fee: $66.00

Begin Time: 
10:00 AM Pacific Time
11:00 AM Mountain Time
12:00 PM Central Time
1:00 PM Eastern Time

CPE Credit: 
1 hour for CPAs
1 hour Federal Tax Related for EAs and OTRPs
1 hour Federal Tax Law for CTEC

This webinar's focus is on the Global Intangible Low Tax Income ("GILTI"). The GILTI is an outbound anti-base erosion provision. GILTI reduces the incentive to shift corporate profits out of the United States via base shifting a corporation's principal asset, intellectual property ("I.P.").

The GILTI is an outgrowth of the Tax Cuts and Jobs Act of 2017 ("TCJA"), the United States congressional revenue act that amended the Internal Revenue Code of 1986. Significant changes included reducing tax rates for businesses and individuals, reducing the alternative minimum tax ("AMT") for individuals, and eliminating AMT for corporations.

The GILTI rules were created by the TCJA and operated as a worldwide precaution to the territorial-style regulations adopted by the tax reform legislation. Further, the GILTI provisions augment the current anti-abuse regime known as Subpart F.  After determining a CFC's Subpart F income, U.S. shareholders have to decide whether they are subject to tax on the CFC's GILTI. The new territorial participation exemption does not spare foreign income classified for U.S. tax purposes as Subpart F or GILTI.

The GILTI is the U.S. response to a global focus on "base-shifting" since 2015, when the OECD finalized the Base Erosion and Profit Shifting ("BEPS") initiative. These initiatives' primary focus is shifting taxable income to low tax and haven countries via Intellectual Property ("I.P.") exploitation. Often, in today's high tech, digital, and online economy, the most valuable and profit-generating assets owned by a firm is its I.P. Judicious tax planning enables a Multinational Company to earn income from exploiting these assets' low tax countries, shielding them from taxation.

Who Should Attend:
Tax Directors, Tax Staff, Transfer Pricing Practitioners, Treasury, Internal Audit, Tax Attorneys, CPAs and CFOs

Topics Covered:

-What is Section 951(A) and the transition tax under Section 965?
-Form 8992
-What is the update to Form 8992, which reflects a U.S. shareholder's calculation of specified interest expense using the netting approach under Treasury  Regulation §1.951A-1(c)(3)(iii)?
-What is Foreign Derived Intangible Income ("FDII"), and how does it relate to GILTI?
-Participation exemption
-What are "supernormal" returns, or returns above 10 percent of qualified investments?
-What are the "net tested income" and the "Qualified Business Asset Investment" aspects of GILTI?
-"One CFC" approach of GILTI
-Effective Dates of the Regulations
-The future scheduled changes and associated impacts of GILTI

For more information and to register, click here.