Kirsten Burmester Analyzes Cross-Border Matters at 31st Annual Institute on Current Issues in International Taxation
December 13, 2018, 4:45 PM - 5:45 PM
| Panelist: | Kirsten Burmester |
| Program: | Cross-Border Individual Matters |
| Event Sponsor: | The George Washington University Law School and IRS, 31st Annual Institute on Current Issues in International Taxation |
| Where: | JW Marriott
1331 Pennsylvania Avenue
Washington, DC 20004
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| Registration: | Click Here To Register |
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).