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

4:45 PM - 5:45 PM

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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