2021 Marcus Evans Tax Summit
2021 Marcus Evans:
Repatriation Modeling Webinar
Special 3-Hour Session
December 8, 2021
1:00 PM – 4:00 PM Central Time
The Tax Cuts and Jobs Act (“TCJA”) dramatically changed the U.S. income tax treatment of the repatriation of foreign earnings. Now, even though IRC Section 245A allows a 100% Dividends Received Deduction (“DRD”) on dividend remittances to corporate shareholders, much of those earnings will have already been subject to U.S. income tax under either the GILTI or Subpart F regime. As a result, many distributions will be out of previously taxed earnings and profits (“PTEP”).
In this session, special attention is paid to the long-established distribution ordering rules prescribed by IRC Section 959 and the Treasury Regulations thereunder. We also explain how those rules have been modified as a result of the Section 965 transition tax and the creation of multiple PTEP accounts and the priority given to Section 965 PTEP accounts within each of the Section 959 layers. PTEP distributions can result in significant foreign exchange gains and losses, and foreign tax credits may be allowed on any additional foreign taxes incurred on PTEP distributions, subject to complex requirements.
During this webinar we will walk participants through the impact of these rules, both by an analysis of the regulation examples, as well as performing how-to-model calculations using Forte’s VantagePoint software.
Understand the distribution ordering rules outlined in IRC Section 959 and the special adjustments relating to Section 965 PTEP Accounts.
Understand how additional income taxes paid on previously taxed income are available for foreign tax credit purposes.
Understand the importance of repatriation modeling for income tax provision purposes.
Discuss how each of the tax requirements is reported on the related international tax forms.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Three (3)
Insights & Press
VantagePoint™ performs comprehensive global tax calculations, including GILTI, FDII, FTC and BEAT in real-time.
Forte has a customized approach utilizing VantagePoint that ranges from consulting engagements to a full license of the software.
“With passage of the tax reform legislation, there were many new provisions, including GILTI, FDII, BEAT, and 163(j), that needed to be dealt with…[VantagePoint] was pretty far advanced and ready to go.”
TAX EXECUTIVE INSTITUTE
TAX TECHNOLOGY CORNER
Check out the second installment of “Tax Technology Corner” where Tax Executive Institute explores how Forte helps multinationals solve today’s most complex tax challenges using VantagePoint™ Global Tax Software.
Forte combine international tax expertise in conjunction with the most advanced, versatile, and powerful global tax software tool in the industry.
Forte focus specifically on those areas of international taxation that have the greatest impact on U.S.-based multinationals and exporters.