Tax News

CCH (cch.taxgroup.com) reports:

Scheduled for Thursday, July 19, 2007
U.S. taxpayers generally do not have to pay tax on income earned by their foreign subsidiaries until cash is repatriated, typically in the form of a dividend. However, the subpart F controlled foreign corporation (CFC) and passive foreign investment company (PFIC) regimes end deferral on mobile/passive income earned by foreign corporations, regardless of whether the income has been distributed, which can present severe tax and cash-flow consequences to U.S. taxpayers.
CCH Tax and Accounting has scheduled a two-hour audio seminar that will address planning opportunities in connection with subpart F and PFICs. To be presented by experienced international tax and business practitioners, Robert J. Misey, Jr., and Adam Konrad on Thursday, July 19, at 1 p.m. Eastern; noon Central; 10 a.m. Pacific, the seminar will offer a nuts-and-bolts discussion on the subpart F rules designed to prevent U.S. taxpayers from avoiding U.S. tax by shifting passive or other highly mobile income through foreign subsidiaries in low-tax jurisdictions. The seminar also will provide ideas on how to avoid having a foreign corporation qualify as a CFC or PFIC. Professionals in public practice and in industry will benefit from this presentation and will come away with a practical understanding of the U.S. anti-deferral regime rules. The presentation time will include ample opportunity to ask questions of Mr. Misey and Mr. Konrad.
With respect to subpart F, Misey and Konrad will discuss:
--The definition of a controlled foreign corporation and how to avoid becoming a CFC;
--The inclusion for foreign base company income, including foreign personal holding company (FPHC) income, foreign base company sales income and foreign base company services income;
--Special exclusions and inclusions under subpart F;
--The inclusion for earnings invested in U.S. property; and
--Eliminating double taxation for subpart F inclusions.
With respect to PFICs, Misey and Konrad will discuss:
--The definition of a passive foreign investment company and how to avoid PFIC status;
--Taxation of PFICs under the excess-distribution regime; and
--Taxation of PFICs that make a qualifying electing fund (QEF) election.
The learning objectives for this seminar are:
--Identify the types of income that are considered subpart F income;
--Understand how CFCs and PFICs are defined and their tax treatment;
--Identify the mechanism to prevent double taxation of subpart F income; and
--Describe how the deemed paid foreign tax credit works in the context of subpart F income.
Registration can be completed online at https://www.krm.com/cch or by calling 1-800-775-7654. Participants can receive two hours of CPE credit. Each site that registers for this seminar will also receive an issue of CCH's Practical Guide to U.S. Taxation of International Transactions (Fifth Edition).