SLW Speaks at CalCPA International Tax Conference
On November 17, Krystle Chow (Partner) and Jordan Reichelt (Senior Manager) presented at the CalCPA International Tax Conference in Universal City, CA.
See our session during the virtual conference
On December 5, our session will be re-broadcasted. Use code CW1122 for a discount
In this session, we will provide an overview of the treatment of income under the two anti-deferral regimes for controlled foreign corporations: subpart F income and GILTI. It is essential to understand the commonalities and differences between subpart F and GILTI, as both can apply in a given tax year to the same taxpayer. While both regimes can generate deemed income for the shareholder, the targeted income and activities vary between the two regimes.
Topics Covered:
History and concept of anti-deferral regimes
Common types and situations of subpart F
Special rules and exceptions in subpart F
GILTI overview
Special rules and exceptions in GILTI