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Repatriation After TCJA

  • AFSP
  • CPA (US)
  • EA
  • Tax Preparer
  • CTEC
Repatriation After TCJA

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-00752-21-O)

1 CE credit of Federal Tax Subjects for California Tax Professionals (CTEC Approved - 6273) (Approval No. 6273-CE-0700)

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

1 CE credit of Federal Tax for Oregon Tax Preparers (Approval No. GEHNZ-T-00752-21-O)

1 CE credit of Federal Tax for Maryland Tax Preparers (Approval No. GEHNZ-T-00752-21-O)

1 General Educational credit for Tax Professionals / Bookkeepers / Accountants

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Course Description

Worldwide taxation? Water’s edge? Repatriation? The world changed a lot after the Tax Cuts and Jobs Act. The “deemed repatriation” provisions of the tax overhaul law present tax advisers to U.S. taxpayers engaged in foreign business and investment activities with an almost immediate compliance challenge. These deemed repatriation provisions, changes to the definition of who is a U.S. shareholder, and changes in attribution rules to determine CFC status. Tax advisers need to immediately grasp the details of the new provisions to avoid costly tax consequences for their clients engaged in cross-border activities.

Tax repatriation is the process by which multinational companies bring overseas earnings back to their home country. Before the 2017 Tax Cuts and Jobs Act (TCJA), the U.S. tax code created significant disincentives for U.S. companies to repatriate their earnings the TCJA eliminated those disincentives.

To avoid double taxation, local income taxes paid on foreign-sourced income by an MNE were generally creditable on the U.S. tax return.

No U.S. tax was due on foreign-sourced income until dividends were paid, i.e., offshore earnings repatriated.  This deferral of taxes on income earned offshore was of obvious benefit on a present value basis.  Thus, companies held gains offshore and deferred U.S. tax liability.

The TCJA enacted reforms that arguably created a territorial taxation system except for introducing the GILTI regime (Global Intangible Low-Tax Income). GILTI, akin to subpart F, expanded the current tax on income earned by companies (CFCs) controlled by U.S. shareholders. In effect, the TCJA moved the U.S. international tax system from one that allowed almost unlimited deferral of tax on foreign earnings to one that now imposes a type of minimum tax on those earnings. 

Major topics covered in the CPE webinar:

  • Worldwide, Territorial, and Quasi-worldwide tax systems
  • Deferral and Anti-deferral
  • Subpart F
  • The effect of the repatriation tax (transition tax) on tax liability 
  • Addressing pre-TCJA earnings deferral – IRC Section 965
  • Post-TCJA – GILTI and Section 951
  • How the composition of overseas funds affects repatriation 
  • The potential impact of repatriated funds due to TCJA on firm financing patterns and investment decisions
  • Biden administration changes to TCJA 

The knowledge about repatriation is especially important today as the IRS has aggressively increased scrutiny and enforcement activity in the international tax area.                                                                                                                                                                                                                                  

Learning Objectives

  • To describe the notion of deferral
  • To differentiate between worldwide vs. territorial taxation
  • To discuss the basics of the one-time transition tax  
  • To determine how IRC Section 965 “transition tax” works
  • To describe how IRC Section 951 on global intangible low-taxed income eliminated U.S. shareholder deferral of earnings in CFCs

Who Should Attend?

  • Annual Filing Season Program
  • Bookkeepers & Accountants & Tax Preparers
  • California Registered Tax Professional
  • CPA (Industry)
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • Enrolled Agent
  • Maryland Tax Preparers
  • Oregon Tax Preparers
  • Tax Accountant (Industry)
  • Tax Attorney
  • Tax Director (Industry)
  • Tax Firm
  • Tax Managers
  • Tax Practitioners
  • Tax Preparer
  • Tax Professionals
  • Tax Pros
  • Trust & Estate Tax Professional
  • Young CPA