transcript   Transcript

The International Tax Reform Provisions—Part 1

Recorded on: Feb. 5, 2018
Running Time: 01:12:25

Full Transcript:



If you are a Privileged Member, just log in and start reading now! If you are not a Privileged Member, please click here to learn how unlimited access to PLI programs may be right for you and your firm.

To access the streaming media of this presentation, please purchase the corresponding seminar segment.

Taken from the Web Program The Tax Cuts and Jobs Act: Navigating the New Landscape Recorded February 2018 in New York

The International Tax Reform Provisions—Part 1 [01:12:25]

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam.

Upon the successful completion of this program, the participant will be able to:

  • Recognize the key developments with respect to the transition tax imposed on deferred foreign income pursuant to Internal Revenue Code (IRC) §965.
  • Recall the participation exemption and the dividends received deduction (DRD) for foreign earnings from 10%-owned foreign corporations pursuant to Internal Revenue Code (IRC) §245A.
  • Identify the global intangible low-taxed income (GILTI) provisions of Internal Revenue Code (IRC) §951A.

Course Overview:

This program will focus on:

  • The key developments regarding the transition tax imposed on deferred foreign income pursuant to Internal Revenue Code (IRC) §965.
  • The participation exemption and the dividends received deduction (DRD) for foreign earnings from 10%-owned foreign corporations pursuant to Internal Revenue Code (IRC) §245A.
  • The global intangible low-taxed income (GILTI) provisions of Internal Revenue Code (IRC) §951A.

CPE Program Level:  Overview

Intended Audience:  CPA’s, tax accountants, tax lawyers, shareholders, taxpayers, and others seeking  the latest information on the implications of the Tax Cuts and Jobs Act (TCJA) with respect to deferred foreign income and foreign earnings.

Prerequisites:  A general knowledge of the treatment of deferred foreign income and foreign earnings pursuant to the latest provisions of the Internal Revenue Code (IRC).

Advanced Preparation:  None

Instructional Method:  QAS Self-Study

Updated:  March 2018

Credit Information:  1 CPE credit is available upon completion of this program’s 3 content-review questions and a minimum passing score of 70% on the 5-question final exam.


Presentation Material

  • Davis Polk Client Memorandum: GOP Tax Cuts and Jobs Act: Preview of the New Tax Regime (December 20, 2017) - Handout
    David H. Schnabel
  • Tax Reform: Transition Tax, 245A, GILTI and FDII
    Neil J. Barr, John E. Harrell
(s)
Neil J. Barr ~ Davis Polk & Wardwell LLP
John E. Harrell ~ Global Tax Director, General Electric Capital
Aaron H. Junge ~ Tax Counsel, House Ways & Means Committee
Marjorie A. Rollinson ~ Associate Chief Counsel (International), Internal Revenue Service
Dana L. Trier ~ Davis Polk & Wardwell LLP
Brenda L. Zent ~ Special Advisor on International Taxation, Office of Tax Policy, U.S. Department of the Treasury
Share
Email
Transcript FAQ's
  • How Can I Access Transcripts?
    You must be a Member in good standing.

  • Can I access the Video?
    Yes, you can access the video if you have the Adobe Flash plugin installed. Click on the video camera icon when you mouse over each paragraph. The media will begin playback at that point.

  • Can I get CLE credit for reading the transcript?
    No, CLE credit cannot be earned for reading a transcript. CLE credit is issued only for verified attendance while watching a web program. If seeking credit, please verify the program's eligibility for credit and expiration date in your jurisdiction on the web segment launch page before commencing the program.

  • FOLLOW PLI:
  • twitter
  • LinkedIn
  • YouTube
  • RSS

All Contents Copyright © 1996-2018 Practising Law Institute. Continuing Legal Education since 1933.

© 2018 PLI PRACTISING LAW INSTITUTE. All rights reserved. The PLI logo is a service mark of PLI.