This session breaks down the sweeping international tax changes introduced under the OBBBA and other new laws. Attendees will learn how revised GILTI rules, Section 250 deductions, downward attribution, tariffs, and remittance tax developments affect cross-border planning. OECD Pillar Two updates will also be covered to help advisors anticipate global compliance challenges. 

This hands-on session provides a practical walkthrough of Form 5471—from earnings and profits to Section 959 ordering and repatriation mechanics. Participants will gain a clearer understanding of how to move cash out of a CFC and apply dividends-received deductions effectively. 

Get an update on recent guidance under 2025-02 involving hybrid and reverse-hybrid entities. This session explains the tax treatment, compliance issues, and cross-border planning implications affecting multinational structures. 

This session provides a timely, multidimensional overview of expatriation for globally mobile individuals and families. The discussion will outline the current expatriation process, recent timelines, and challenges at embassies and borders, as well as how the political climate is influencing decisions to relinquish U.S. citizenship. Additional topics include re-entry considerations, second-passport requirements, and the potential implications of proposed programs such as the Trump Gold/Platinum card initiative. The session will also cover core tax compliance obligations and key components of the exit tax, including the $2 million net worth test. Practical planning strategies, risk areas, and collaborative attorney–CPA coordination points will equip advisors with the knowledge needed to guide clients contemplating or completing expatriation in today’s rapidly evolving environment.  

Learn the different tax regimes applicable to corporate versus noncorporate U.S. shareholders of Controlled Foreign Corporations, when indirect noncorporate U.S. shareholders are eligible to be taxed under the corporate regime, the impacts of such an election, and a framework for analyzing when these elections may provide strategic tax benefits. 

This session helps professionals identify foreign pensions, understand their structures, and determine how they are taxed in the U.S. The discussion includes PFIC concerns, reporting considerations, and common traps practitioners encounter when advising cross-border clients.

Learn how to apply foreign tax credits in real-world scenarios for individuals and CFCs. Topics include Form 1116, Form 1118, FTC limitation rules, and planning considerations for clients with complex international tax footprints.