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