This session, from TEI’s 2025 International Tax Course, provides tax professionals with a comprehensive introduction to the U.S. Anti-Deferral Regimes, including Subpart F and the Global Intangible Low-Taxed Income (GILTI) provisions. Designed for professionals seeking a comprehensive refresher or adding additional responsibilities to their current roles, this session explores the historical background and current application of controlled foreign corporation (CFC) rules, income inclusions, and GILTI calculations.
Learning Outcomes
- Explain the historical background and current application of Subpart F, including the rules for controlled foreign corporations (CFCs) and Sections 958(a) and 958(b).
- Identify and evaluate the implications of Subpart F income rules and their application to controlled foreign corporations in the context of U.S. international tax law.
- Understand the concepts of Global Intangible Low-Taxed Income (GILTI), including net tested income and loss, and their role in the US anti-deferral framework.
Who Should Attend
This session is designed for tax professionals involved in international tax matters, those transitioning to a new tax practice area within their company, or those taking on new responsibilities, including tax advisors, corporate tax professionals, CPAs, tax managers, and international tax lawyers. It will benefit professionals seeking a comprehensive introduction to the U.S. Anti-Deferral Regimes, including Subpart F and the Global Intangible Low-Taxed Income (GILTI) provisions.
Instructor(s)
Kris Hatch, Associate, Fenwick & West LLP
William Skinner, Partner - Tax, Fenwick & West LLP
General Session Information
Access
Online, upon completion of the checkout process, you will be directed to our Learning Management System (LMS) for access to the session.
For member pricing, please login to tei.org
This is a digital product. With full paid access, the content will be available for one year after the purchase date.
CPE Credits
This digital product is not eligible for Continuing Professional Education (CPE) credit and includes the recording from the 2025 in-person session and the corresponding PowerPoint slides.
Length of Session
The session will take approximately 3.5 hours to complete.
NASBA Field of Study
Taxes
Level
Basic
Prerequisites
None
For more information, please refer to CPE requirements and NASBA sponsorship information.
Terms & Conditions
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