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Global Intangible Low-Taxed Income and Form 8992

  • AFSP
  • CPA (US)
  • EA
  • Tax Preparer
  • CTEC
Global Intangible Low-Taxed Income and Form 8992

1 Credit

$10

Subject Area

Taxes

Webinar Qualifies For

1 CPE credit of Taxes for all CPAs

1 CE credit of Federal Tax for Enrolled Agents ( IRS Approved : GEHNZ ) (Approval No. GEHNZ-T-00558-21-O)

1 CE credit of Federal Tax Subjects for California Tax Professionals (CTEC Approved - 6273) (Approval No. 6273-CE-0538)

1 CE credit of Annual Filing Season program (AFSP)( IRS Approved : GEHNZ )

1 CE credit of Federal Tax for Maryland Tax Preparers (Approval No. GEHNZ-T-00558-21-O)

1 CE credit of Federal Tax for Oregon Tax Preparers (Approval No. GEHNZ-T-00558-21-O)

1 General Educational credit for Tax Professionals / Bookkeepers / Accountants

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IRS Form 1099 Reporting Req. including updates on FORM 1099-NEC (LATEST 2021)

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Course Description

This online CPE 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 operate as a worldwide precaution to the territorial-style rules 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, US shareholders have to determine if 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. A major focus of these initiatives is the shifting of taxable income to low tax and haven countries via Intellectual Property (“IP”) exploitation.  Often, in today’s high-tech, digital, and online economy, the most valuable and profit-generating assets owned by a firm is its IP. Judicious tax planning enables a Multinational Company to earn income from the exploitation of these assets in low-tax countries shielding them from taxation.    

In this online CPE webinar, the following key topics are covered:

  • What are section 951(A) and the transition tax under section 965? 
  • What is Form 8992?  
  • What is the update to Form 8992 which reflects a US 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? 
  • What is the 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 
  • What is the "one CFC" approach of GILTI 
  • What are the Effective Dates of the Regulations? 
  • What are the future scheduled changes and associated impacts of GILTI? 

Learning Objectives

  • To discuss the differences between international tax systems: world-wide, territorial, and destination-based.
  • To discuss the relationship between section 951(A) and section 965’s transition tax.
  • To elaborate how to fill out form 8992.
  • To discuss the TCJA shift from a Global Tax to a Territorial One.
  • To discuss the importance of the TCJA Participation Exemption.
  • To discuss how GILTI and FDII incentivize U.S. Businesses to keep I.P. related profits in the U.S.
  • To evaluate the Tax Planning Impacts of GILTI.

Who Should Attend?

  • Accounting Firm
  • Bookkeepers & Accountants & Tax Preparers
  • California Registered Tax Professional
  • CPA (Industry)
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • Maryland Tax Preparers
  • Oregon Tax Preparers
  • Staff of Accounting Firm
  • Tax Accountant (Industry)
  • Tax Attorney
  • Tax Director (Industry)
  • Tax Firm
  • Tax Managers
  • Tax Practitioners
  • Tax Preparer
  • Tax Professionals
  • Tax Pros
  • Young CPA