U.S. Tax Reform Fiscal Year End Section 965 Entities & PTI Post Section 965
International Tax Meeting - October 23, 2018
Sponsored by KPMG LLP
KPMG is hosting a tax workshop to discuss computation and planning considerations with respect to: the section 965 issues that fiscal year-end taxpayers should consider; the importance of previously taxed income (“PTI”) post-section 965 inclusions; global intangible low-taxed income (“GILTI”) proposed regulations; and tax planning opportunities under the current tax regime.
Program:
8:00 a.m. - 8:30 a.m. | Registration and continental breakfast
8:30 a.m. - 12:00.p.m. | Technical session
Agenda:
1) Computational Issues under 965
a. Foreign Tax Credits
i. FTC Haircut
ii. Section 78 Gross-Up
iii. Allocation of FTC Between Subpart F and Section 965
b. Traps for Unwary
i. SFC to SFC transactions
ii. Dividend Distributions
c. Accounting Methods vs Error
d. Checklist
i. Audit Work Plan
ii. Compliance
iii. Filing
2) PTI Discussion
a. Basis Election
i. 961(b) Basis
b. PTI
i. APB23
ii. PTI Distribution Ordering
iii. 986(c) - FX Gain/Loss on Distribution
c. GILTI Basis
3) GILTI
a. Highlights of the Proposed Regulations
4) M&A
a. Section 965(h) – Acceleration of 8 Year Installment
b. Section 338(g) Elections
c. E&P and Section 1248 Planning
Fee for this program is $50 and approximately 3 CPE credits will be earned by attendees. To register click this link: https://teinychaptermeeting102318.eventbrite.com