Strafford Tax Training Offers Webinar on the Final Regulations for the Section 965 Foreign Deemed Rep
By: Expat Tax Tools
In January 2019 the IRS finalized its previously issued proposed regulations on calculating the transition tax. While the final regulation accepted most of the proposed guidance, the Service provided clarification on a pair of critical issues for corporate taxpayers. The final guidance provides a narrow exemption from the definition of "cash position" in determining the amount of transition tax a specified foreign corporation must report. Additionally, the Service offered clarification on the loss aggregation calculations for consolidated groups.
The key issues to be discussed include:
Determining the applicability of Section 965 to specific U.S. shareholders
Identifying what is cash vs. non-cash for purposes of foreign-source income and applicable tax rates
The use of NOLs and determining taxable foreign-source income
New guidance governing consolidated returns and loss allocations
Application of anti-avoidance rules to E&P reducing transactions
For more information you can visit our website - http://bit.ly/
Mary Beth Lougen is Chief Operating Officer of Expat Tax Tools. Mary Beth has over 35 years of Income Tax experience, working both in the United States and in Canada. As an exceptional researcher, Mary Beth constantly monitors the ever changing US tax law and regulations to keep her team abreast of the latest developments enabling a broader understanding of international taxation, domestic taxation, and tax treaty interpretation. Her progressive experience in US international taxation and reporting, coupled with her hands on leadership is a proven combination to provide clients with a confidence that their tax needs are being met with professionalism and integrity. Mary Beth has a Masters in Legal Studies in Taxation, carries the title Enrolled Agent which is the highest credential given out by the IRS and is also U.S. Tax Court Practitioner, and a respected writer and teacher in cross-border taxation.
Stafford is a professional training and coaching firm that provides Premium CLE and CPE courses designed for leading professionals in over 40 legal, accounting, and tax practice areas.
Mary Beth Lougen