Kirsten Burmester Analyzes Cross-Border Matters at 32nd Annual Institute on Current Issues in International Taxation
This panel will discuss recent developments impacting the taxation of outbound and inbound cross-border investments by individuals. Specific topics covered may include:
- GILTI and other outbound planning issues for individual U.S. shareholders, including how the proposed GILTI high-tax exception may impact an individual’s decision to make a section 962 election.
- Implications of section 958 on U.S. individual ownership of foreign corporations through domestic partnerships, including the effect on PFICs.
Lingering section 965 issues for individuals.
Practical issues raised by the proposed section 1446(f) regulations.
Tax treaty application to individuals.
FIRPTA and other international tax issues for foreign investors in qualified opportunity zones.