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Monday, November 6, 2023 Live Webcast

U.S. Taxation of Foreign Corporations: A Case Study Approach (E2311662)

1:00 PM - 3:40 PM EDT

Registration: 12:30 PM EDT


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3 CPE Credits in TX


This course is a case study designed to provide a comprehensive overview of U.S. taxation of a foreign corporation. Using a specific example, the course will walk through step-by-step mechanics on how to calculate the income inclusions and foreign tax credits under GILTI (Global Intangible Low-Taxed Income), Subpart F, and PFIC (Passive Foreign Investment Company) regimes. The case study will further evaluate tax impact of subsequent distributions from the foreign corporation and sales of its stock. A compare-and-contrast approach will highlight the different outcomes of these regimes for individuals and for C corporations, empowering participants to advise their clients on the most tax efficient way to structure their international investments.

This course features a live instructor and has been specifically designed for the NJCPA.


Any tax practitioner with clients invested in a foreign corporation


  • Explain the similarities and differences between GILTI, Subpart F, and PFIC regimes
  • Understand the mechanics of income inclusions and foreign tax credits available under GILTI, Subpart F, and PFIC regimes
  • Compare and contrast the overall tax liability under different circumstances
  • Identify tax planning opportunities for income from foreign corporations


  • Understand how to approach and analyze the U.S. taxation of foreign corporations
  • Using an example, calculate GILTI, Subpart F, and PFIC income inclusions for an individual and C corporation
  • Determine how much foreign tax credit can be claimed against such income inclusions
  • Determine how subsequent dividend distributions from the foreign corporation are taxed
  • Calculate capital gain on the disposition of the foreign corporation
  • Discuss the impact of Section 962 election
  • Compare different outcomes under GILTI, Subpart F, and PFIC regimes for individuals and corporations
  • Identify basic strategies for managing tax liabilities related to foreign corporations




A basic understanding of the tax rules relating to individual and corporate income tax




Jason Carney

Jason W. Carney, CPA, CISA, PMP, CISSP, CCSP, Esq.

Jason Carney, CPA, CISA, PMP, CISSP, CCSP, Esq., is a Lead Information Security Analyst with Thomson Reuters. He has more than 15 years of experience in public accounting, consulting, and industry. His specialties include information security, tax problem resolution, and data analysis. Jason has worked in Federal Finance, Information Security, and Tax.

Jason is a member of the Minnesota Bar and was a President’s Scholar at the University of Saint Thomas Law School. He co-founded the Scott County Conciliation Clinic and represents impoverished debtors pro bono in association with the Volunteer Lawyers Network. He wrote “What is Business Intelligence and Why Should CPAs Care?” for Footnote magazine and contributed to the upcoming publication What Every Lawyer Needs to Know About Client Trust Accounts.