The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact pattern.

During this program, McDermott will illustrate some of the benefits and drawbacks that may arise from these regulations, and provide you with practical considerations that will help you navigate the decision as to whether to make an election to apply the global intangible low-taxed income (GILTI) high-tax exclusion. McDermott will discuss:

• Key considerations when deciding to make the election to apply the GILTI high-tax exclusion

• Who is most likely to benefit from making this election

• Main reasons to not elect to apply the GILTI high-tax exclusion

• Traps for the unwary in the proposed subpart F high-tax exclusion regulations

Have an (anonymous) question that you would like us to answer? Be sure to submit it via the registration link.

CLE/CPE CREDIT
Minimum Continuing Legal Education (MCLE) credit is pending in California, Illinois and New York. Attendees who request credit in other states will receive a Uniform Certificate of Attendance, which can be used to claim credit as permitted by applicable state MCLE rules. Continuing Professional Education (CPE) credit is also pending. A Multi-Jurisdiction Certificate will be made available to participants requesting CPE credit.

To be eligible to earn a certificate, you must participate via Zoom and not only by phone, and attend the entire webinar. Credit for partial attendance will not be provided.

ADDITIONAL UPCOMING VIRTUAL TAX FORUM PROGRAMMING
Stay tuned for our additional upcoming programming. Registration details forthcoming.