OBBBA: Stock Attribution, Restoration of Section 958(b)(4), and Section 951B, a New Anti-Deferral Regime
Recording of a 110-minute CPE webinar with Q&A
This webinar will explore the scope and potential impact of the changes to the downward attribution rules and the new IRC Section 951B. Our panel of seasoned international tax practitioners will explain which U.S. shareholders and foreign corporations may be affected and how to prepare ahead of the effective date.
Outline
- Introduction: Downward attribution rules and Section 951B
- Background and the practical impact of Section 958(b)(4) Repeal
- Downward attribution under TCJA
- Compliance challenges, Treasury guidance, and safe harbors
- Restoration of the limitation of downward attribution
- Impact on CFC determination and related tax provisions
- Section 951B as a parallel anti-deferral regime
- Definition and scope of Foreign-Controlled U.S. Shareholder (FCUSS)
- Definition and scope of Foreign-Controlled Foreign Corporation (FCFC)
- Structures potentially affected by Section 951B
- Income inclusions under Section 951B
- Interaction with other tax provisions
- Compliance and reporting requirements
- Transition issues and areas needing Treasury guidance
- Planning ahead: Strategic considerations
Benefits
The panel will address key issues, including:
- Examples and illustrative scenarios
- Assessing the impact of restored downward attribution rules on U.S. persons
- Identifying FCFCs and evaluating their implications
- Understanding Section 951B as a parallel regime
- Scoping the potential impact on U.S. persons with foreign investments
Faculty
Indhira Demorizi, CPA, MST
Chief Executive Officer
illumina CPA Group
Ms. Demorizi founded illumina CPA Group after a distinguished 20+ year career with Deloitte and PwC, serving... | Read More
Ms. Demorizi founded illumina CPA Group after a distinguished 20+ year career with Deloitte and PwC, serving leading private equity and venture capital firms, Fortune 500 companies, private companies, and high-net-worth individuals across the US and globally. Her vision for the company is to play a crucial role in helping middle-market businesses navigate the often complex world of taxation, especially with the added layers of cross-border and international considerations, and to bring practical strategies and solutions throughout the entire lifecycle. Ms. Demorizi's core competencies span various disciplines: US and international tax planning and reporting, M&A deal structuring and tax due diligence, fund and management company structuring, global structuring for private and public companies, supply chain/value chain transformation, Pillar Two assessments, income tax provision/ASC 740, and tax planning for high-net-worth individuals.
Close
Pamela A. Fuller, Esq., J.D., LL.M.
Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Global
Ms. Fuller is a corporate and international tax attorney with over 20 years' experience in advising a wide range of... | Read More
Ms. Fuller is a corporate and international tax attorney with over 20 years' experience in advising a wide range of clients -- including private clients and companies, joint ventures, private equity funds, HNW individuals, C-Suite executives, "start-ups," and government entities -- on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. She has deep expertise in structuring cross-border M&A transactions and advising mobile international families. Her clients hail from a multitude of industries, including the burgeoning world of decentralized finance (DeFi). Pamela is also a seasoned taxpayer advocate, with decades of experience resolving complex U.S. federal, state, and foreign tax controversies.
Close
