Kirsten Burmester Analyzes Cross-Border Matters at 31st Annual Institute on Current Issues in International Taxation

12.13.2018

This panel will discuss the impact of tax reform on individual US shareholders and their closely held businesses, with a particular focus on potential traps and on planning to minimize the adverse consequences of those traps where possible. Specific topics covered may include:

  • Structuring for ownership and operation of CFCs by US individuals after reform.
  • GILTI issues for individual US shareholders, including the potential benefits and drawbacks of Section 962 elections.
  • Issues on exit, including Sections 338(g), 1248(b), and 964(e)(4).
  • Select Section 965 issues for US individual shareholders, including
    Section 96(i).
  • Relevant implications of Section 958(b)(4) repeal, particularly for inbound financing structures.
  • Remaining issues under Section 864(c)(8).

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