Section 951A (GILTI) Final High Tax Exception 2020 Regulations
Author: Adnan Islam
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC |
This course will cover the GILTI high tax exception (2020) regulations, planning issues, and effective tax rate considerations in applying these final regulations. This course will also provide a high level summary of the fundamental GILTI computational rules and corresponding, annual reporting requirements for U.S. Shareholders of CFCs with tested income. GILTI was enacted as new Section 951A under the Tax Cuts and Jobs Act (TCJA), along with subsequent proposed, final (2019 and 2020), and coordinating regulations. Note that both the GILTI and FDII deductions are defined within Section 250.
Publication Date: November 2020
Designed For
Experienced international tax staff through international tax director level interested in or already practicing international taxation.
Topics Covered
- Section 951 Overview
- What is GILTI?
- GILTI high tax exception regulations summary and highlights
- GILTI High”Tax Exclusion: Computational Steps
- Practical considerations for applying the GILTI high tax exception
- Subpart F Income High Tax Exception July 2020 Proposed Regulations
- Common Questions
Learning Objectives
- Identify the GILTI high tax exception under Treas. Reg. 1.951A-2
- Recognize the basic differences between GILTI and subpart F income
- Recognize practical considerations and potential issues that may negatively impact a taxpayer's effective tax rate when assessing the GILTI high tax exception.
- Identify the GILTI Pro Rata Inclusion calculation
- Identify the GILTI High”Tax Exclusion Computational Steps
- Identify the GILTI High-Tax Exclusion steps
Level
Overview
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
