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 brings together tax and immigration perspectives to walk through the challenges of expatriation. Participants will gain insights into exit tax rules, residency considerations, planning strategies, and the immigration issues that commonly intersect with tax compliance. 

Learn how OBBBA reshapes the use of Section 962 elections and impacts Controlled Service Corporations. This session highlights planning implications for U.S. shareholders of foreign corporations and analyzes 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.