Today’s International Strategies: Opportunities and Traps

The Tax Cuts and Jobs Act (TCJA) ushered in massive changes for US based multinationals. Pass-through entities saw significant changes in the treatment of foreign income and activity which is giving rise to planning and compliance challenges. This session with take a practical look at international pass-through entities and the ramifications of the post TCJA regulatory changes. We will discuss the adoption of the aggregate theory for U.S. partnership owned CFC’s and the related tax considerations including tax basis adjustments, treatment of previously taxes income and the CFC/PFIC overlap rules. While additional guidance on several of these matters is almost certain in the future, taxpayers facing current planning and compliance challenges must navigate the complexity while managing risk without guidance in several key areas.