Kirsten Burmester Analyzes Cross-Border Matters at 32nd Annual Institute on Current Issues in International Taxation

12.19.2019

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.

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