Essentials of SALT and Understanding Subpart F Inclusion & GILTI

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Corporate Tax Fundamentals Series: Essentials of State & Local Income Tax and Understanding Subpart F Inclusion & GILTI

July 23, 2019

Corporate Tax Fundamentals
Sheraton Parsippany Hotel
199 Smith Road
Parsippany-Troy Hills, NJ 07054

Global Tax Management (GTM) invites you to attend our next Corporate Tax Fundamentals session – a series of 2-hour events designed to educate junior tax professionals and/or act as a refresher for senior level tax professionals.

Delivered in a format that is practical, timely, and adaptable, this training series is meant to deepen the tax knowledge of the corporate tax department without disrupting the entire day.

Please join us on August 9th for breakfast, networking, 2 CPE credits, and a comprehensive education on the topics of International Tax (Subpart F and GILTI) and State & Local Income Tax (Nexus Standards, Public Law 86-272, apportionment, and state updates).

Here’s what you will learn:

Here’s what you will learn:

Session 1: International Tax – Understanding Subpart F Inclusion & GILTI

Subpart F Inclusion

  • Definitions related to the Foreign Corporation Anti-Deferral Regimes:
    • What is a Controlled Foreign Corporation (CFC)?
    • What is a Foreign Personal Holding Company (FPHC)?
    • What are Passive Foreign Investment Companies (PFIC)?
    • Overview of Subpart F – the Foreign Anti-deferral Regime:
      • What is Subpart F and why was it created?
      • Examples of potential abuse targeted by Subpart F
      • How to calculate and report Subpart F on Form 5471

Global Intangible Low -Taxed Income Inclusion (GILTI)

  • GILTI overview
  • Steps in calculating GILTI:
    • What is tested income and tested loss?
    • What is Qualified Business Asset Investments?
    • What is specified interest expense and how does it affect the GILTI calculation?
  • Example of how to calculate GILTI and report it on the new Form 5471

Presenter: Jarek Filak, Senior Manager, International Tax Services, Global Tax Management

Session 2: Essentials of State & Local Income Tax

  • Understanding State Nexus standards
  • The basics of Public Law 86-272 (The Interstate Income Act of 1959)
  • Apportionment methodologies: cost of performance vs. market-based apportionment
  • Important State updates pertaining to:
    • 163(j)
    • GILTI
    • Net Operating Losses (NOLs)

Presenter: Tom Fazio, Associate Director, Global Tax Management

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