The question is how does one figure out what the tax is; followed by how does one decide when they are going to pay the tax?
A United States shareholder of a deferred foreign income corporation is allowed a deduction in the year of the income inclusion under Section 965(c) equal to the 8 percent rate equivalent percentage, and the 15.5 percent rate equivalent percentage. The 8 percent rate equivalent percentage is the percentage that would result in the income inclusion under Section 965(a) being subject to a US tax at a rate of 8%. The 15.5 percent rate equivalent percentage is the percentage that would result in the income inclusion under Section 965(a) being subject to a U.S. tax at a rate of 15.5%. This video reviews the computation of the tax, as well as the payment of the tax.
Agenda
Faculty
Charles S. Kolstad
Withers Bergman LLP
- Tax partner Withers Bergman LLP, a leading international private capital law firm, specializing in international tax matters
- Focuses his practice on international tax, corporate, and partnership matters; he assists clients in tax and corporate planning relating to the acquisition, disposition and restructuring of businesses, corporations and partnerships both domestically and internationally
- Frequently advises foreign individuals moving to the U.S. on pre-immigration, income, gift and estate tax planning opportunities; he also focuses his practice on the cannabis industry/cannabusiness, crypto assets and block chain technology, and tax issues related to initial coin offerings (ICOs)
- Has advised over 200 clients with unreported foreign 1nancial accounts, foreign trusts, and other foreign investments, on the 1ling of FBARs and other information returns, and whether participating in the IRS’s various offshore voluntary disclosure programs is appropriate
- Written and lectured on the extensive information reporting requirements for U.S. taxpayers with international business operations
- During his career he’s been at Mitchell Silberberg & Knupp LLP and Venable LLP and was a tax partner at both Coopers & Lybrand and Ernst & Young
- J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University
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