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Tax Reform's Impact on Other Subpart F Modifications and Inbound Transactions

Tax Reform's Impact on Other Subpart F Modifications and Inbound Transactions

Quick Overview
The monumental passage of the 2017 Tax Cuts and Jobs Act resulted in historic tax reform affecting nearly every American. This CPE course provides a comprehensive overview of the changes affecting individuals and families, as well as critical financial planning considerations and strategies.

Credits - 2.00
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David Sites, CPA, Grant Thornton

Field(s) of study


Level of difficulty


Topics discussed

Overview of international tax reform, Overview of business provisions (non-international), Rate cut, Cost recovery, IRC Section 163(j), Modification of NOL rules, Carried interest, Sale and exchanges of partnership interests, The international provisions, Other Subpart F modifications, Modification of IRC Section 958(b)(4), Modification of the definition of “US shareholder”, Elimination of 30-day control requirements, Other, Prevention of base erosion (outbound), IRC Section 936(h)(3)(B) changes, Hybrid transaction rules, No 1(h)(11) rate for "inverted" companies


Recognize the basic provisions enacted by the Tax Cuts and Jobs Act, Identify the major international provisions of the new income tax laws, Determine how the significant changes to international tax laws should be applied

Designed for

CPAs, tax professionals, and other qualified professionals with basic knowledge of, and interest in, international tax, Management accountants and business team members involved in corporate tax function