As the majority of the 2017 Tax Cuts and Jobs Act (TCJA) provisions near their expiration date, federal policymakers in 2025 will be faced with fracturing coalitions and difficult choices as they debate how to address TCJA’s changes to individual, international, and corporate taxes. Come learn how post-election outcomes will influence the scope and size of possible federal tax policies in 2025 – and whether the current political environment allows for significant changes in international tax policies. 

This session delves into the complexities of entity classification through Form 8832, focusing on foreign disregarded entities and their tax implications. Topics include the how-and-why’s of Form 8832, hybrid entities, and the strategic use of Form 8858. Gain clarity on the "can you, how do you, and when should you" questions to optimize compliance and planning for cross-border clients. 

Stay ahead of the curve with a review of the latest foreign trust regulations published by the IRS. This session provides essential updates and insights into navigating these complex rules, equipping professionals to advise clients with cross-border trust arrangements confidently. 

In this session, we will explore the fundamentals of Form 3520, including the definition of a foreign trust, disclosure requirements and tax implications for foreign grantor trusts vs. nongrantor trusts, and reporting of gifts and inheritance from foreign persons. 

This session provides a comprehensive guide to navigating the complexities of Passive Foreign Investment Companies (PFICs), including identification, tax implications, and available elections. Dive into strategies for correcting compliance failures, explore the proposed PFIC regulations, and gain practical insights through a detailed walk-through of the required forms. 

This session will provide an overview of foreign exchange issues under sections 987, including proposed and/or final 987 regulations.  

This session unpacks the complexities of Form 5471, focusing on attribution rules, filer categories, and earnings and profits (E&P) considerations. Gain the knowledge needed to ensure accurate compliance and effective planning for clients with international business interests or foreign corporate ownership. 

This session highlights essential due diligence requirements and risk management practices relevant to international tax engagements. Drawing connections across topics discussed throughout the conference, it emphasizes strategies for maintaining compliance and mitigating risks in cross-border tax planning and reporting.