The TCJA made significant changes to how income of controlled foreign corporations is taxed. The operation of the new Global Intangible Low-Taxed Income (GILTI) continues to be molded as guidance is released related to foreign tax credits, previously taxed earnings and profits and foreign-derived intangible income.
Topics discussed:
• Guidance related to foreign tax credit.
• Address the current status of previously taxed earnings & profits (PTEP).
• Explore the impact of the foreign-derived intangible income (FDII) provision and accompanying regulations.
Brandon King, Associate, Baker & McKenzie LLP (moderator)
John Bates, Principal, Deloitte Tax LLP
Robert Russell, Counsel, Kostelanetz & Fink, LLP
Jeffrey L. Parry, Senior Counsel, I.R.S. Office of Chief Counsel (INTL)
James Wang, Attorney-Advisor, U.S. Department of the Treasury
Jason Yen, Attorney-Advisor, U.S. Department of the Treasury
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