* Recognize the basic provisions enacted by the Tax Cuts and Jobs Act * Identify the major international provisions of the new income tax laws * Determine how the significant changes to international tax laws should be applied
* Overview of international tax reform * Overview of business provisions (noninternational) * Rate cut * Cost recovery * IRC Section 163(j) * Modification of NOL rules * Carried interest * Sale and exchanges of partnership interests * The international provisions * Other Subpart F modifications * Modification of IRC Section 958(b)(4) * Modification of the definition of “U.S. shareholder” * Elimination of 30-day control requirements * Other * Prevention of base erosion (outbound) * IRC Section 936(h)(3)(B) changes* Hybrid transaction rules * No 1(h)(11) rate for "inverted" companies
Who Should Attend
* CPAs, tax professionals, and other qualified professionals with basic knowledge of, and interest in, international tax * Management accountants and business team members involved in corporate tax function
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|OD004119: Tax Reform’s Impact on Other Subpart F Modifications and Inbound Transactions||Early Bird||Regular|
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