U.S. shareholders of foreign corporations have a new pass-through income category to contend with: GILTI. Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders. What is GILTI? This session explores the rules, how it affects U.S. shareholders and available countermeasures.
Section 951A. U.S. shareholders of foreign corporations.
CPAs and attorneys.
Identify Section 951A rules and filing requirements. Determine whether foreign income is susceptible to GILTI requirements.
Philip D. W. Hodgen is the principal attorney for Hodgen Law Group, which specializes in the international tax arena. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law.
Admitted to the California bar in 1982, Mr. Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. For six years of his youth, he lived in Rhodesia, South Africa and New Zealand. Mr. Hodgen is a past chair of the International Tax Committee of the State Bar of California’s Tax Section and was a member of the Executive Committee of the State Bar of California’s Tax Section for 2004-2007.
Mr. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, real estate professionals and other groups.
Non-Member Price $59.00
Member Price $49.00