September’s Tax Planning Seminar for CFCs in Philadelphia

Kat Jennings

September 19 is coming up fast. There’s not much time left to sign up for this Tax Planning Seminar.

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

Subpart F income is one of the important issues to be aware of when completing Form 5471, but it is also very difficult to determine. According to I.R.C. Section 952, there are several categories of subpart F income. Attend this seminar to learn about CFCs and the subpart f categories and about several exceptions to the categories of subpart F income to reduce taxes.

These international tax planning seminars are for law firm and accounting firm professionals who advise clients on structuring cross border transactions and on international tax planning matters; in-house tax professionals involved in cross-border and internal planning, in IRS audits and appeals of international issues and tax compliance activities. There is no advance preparation or prerequisites for this group live seminar. (Field of Study: Taxes)

Earn Up to 8 CPE/CLE Credits

Monday, September 19, 2016


8:30 AM – Registration and Continental Breakfast

9:00 AM – Overview of Subpart F Provisions – Basic Mechanics

  • Introduction
  • Controlled Foreign Corporations (Section 958)
  • Subpart F Income Definition and Exceptions (Section 952)
  • Investments in U.S. Property (Section 956)
  • Income Inclusion Requirements and Limitations (Section 951)
  • Calculating the Foreign Tax Credit (Sections 901, 902 and 960)
  • Previously Taxed Earnings (Section 959)
  • Sale of a CFC (Section 1248)
  • Affirmative Use of Subpart F

Jaclyn Obeso Kunkel, Senior Manager, KPMG LLP, Philadelphia
Maya Lupova, International Tax Manager, KPMG LLP, Philadephia

10:30 AM – Refreshment Break

10:45 AM – Section 954(d) – Foreign Base Company Sales Income

  • Foreign Personal Holding Company Income
  • Same-country Exception
  • Active Trade or Business Exception
  • CFC look-through – Section 954(c)(6)
  • Active Financing Income Exception
  • Foreign Base Company Services Income
  • Substantial assistance

John C. Crucs, Managing Director, KPMG LLP, Short Hills, NJ
Brad Kinder, Tax Manager, KPMG LLP, Short Hills, NJ

12:15 PM Luncheon

1:00 PM – Overview of Sections 954(c) and 954(e)

  • Foreign Personal Holding Company Income (FPHCI) defined in § 954(c)
  • Look-through Exception § 954(c)(6)
  • Notice 2007-9 – Anti-Abuse Rules
  • Foreign Base Company Services Income (FBCSI)
  • Substantial Assistance Test Notice 2007-13

Phyllis E. Marcus, Director, PricewaterhouseCoopers LLP, Washington, DC

2:15 PM – Refreshment Break

2:30 PM – Computing E&P and Section 1248

  • Calculation of E&P
  • Overview of Section 1248 and calculation of the Section 1248 amount
  • Foreign tax credit consequences of recognizing Section 1248 amount, interaction with Sections 338(g) and 338(h)(16)
  • Application of §367 to §304 Transactions
  • Final Section 1248 Regulations

James K. Sams, Principal at KPMG LLP, McLean, VA

4:00 PM – Reporting Issues for Controlled Foreign Corporations and Disregarded Entities

  • Reporting Issues for Controlled Foreign Corporations (CFCs)
  • Accounting method changes affecting Earnings & Profits
  • Final GRA compliance regulations
  • Updates concerning IRS Form 5471
  • Recent developments in certain areas of the IRS code and regulations with regard to income tax compliance
  • Creditable foreign tax expenditures §1.704-1T
  • Foreign tax credit – credit vs. deduction

Raymond Wynman, Director International Tax, Global Tax Management, Philadelphia

5:00 PM – Seminar Concludes

Conference Location

Regus Conference Facility
1500 Market Street-12th Floor, East Tower
Philadelphia, PA 19102
(215) 246-3400

Club Quarters Hotel
1628 Chestnut Street (At 17th Street)
Philadelphia, PA 19103
(215) 282-5000

Sonesta Philadelphia Downtown Rittenhouse Square
1800 Market St
Philadelphia, PA 19103

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Kat Jennings, CEO

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