Skip to Content

Navigating foreign entity classification elections and the impact of the proposed Section 367 regulations

Thursday, March 24, 2016
2 p.m. - 3 p.m. EDT
View On-Demand
Taxing foreign subsidiaries is already a complicated matter but, with the addition of the proposed Section 367 regulations, it muddies the waters even more. Join our webinar to learn about foreign entity classification and ensure you’re making the right selections.

Team members having a meeting at a table

U.S. taxpayers have multiple options for electing how the United States will tax their foreign subsidiaries. Many factors go into selecting the appropriate entity classification election, and that selection can have dramatic effects on global tax liabilities.

Complicating matters further are the proposed regulations of Section 367, which have introduced changes that can result in an entity classification election becoming a taxable event.

Learning objectives

At the conclusion of this session participants will be able to (or will know):


  • Identify what entities are eligible to make an entity classification election
  • Understand the U.S. tax treatment of entities with various classifications
  • Recognize the U.S. tax consequences of deemed transactions that occur as part of an entity classification election


  • Bill Henson, International Tax Partner
  • Randy Janiczek, Tax Senior Manager
  • Jessica Wargo, Tax Manager

Related Thinking

Two tax professionals looking at a mobile phone and walking up stairs.
February 8, 2024

India tax change: Royalty and FTS withholding rates increased

Article 3 min read
American, Russian, and Chinese flags against a blue sky.
December 19, 2023

Economic decoupling: Breaking up is hard to do

In The News 5 min read
Business professionals researching and learning about international tax updates.
December 14, 2023

International updates: Tax news and other global updates for Q4 2023

Article 9 min read