Navigating US Taxation of Foreign Business Activities: Regulations that Affect Your New Jersey Clients
Date: Aug 25, 2026 12:00 p.m. – 1:40 p.m.
Location: Online
Member Price: $99.00
Non-Member Price: $125.00
Section Price: $0.00
Areas of Law: Business, International Law & Organizations, Taxation
Keynote
Moderator
Presenters
- Patrick J. McCormick, Esq.
- Gunnercooke LLP, Philadelphia
As businesses increasingly expand across borders and investors pursue opportunities in global markets, it is more important than ever for practitioners to understand the evolving US taxation of foreign business activities. This timely program provides an in-depth analysis of the international tax regime, with a focus on Subpart F income, passive income that is immediately taxed, and Net CFC Tested Income (NCTI), a global minimum tax on active foreign business profits.
Practitioners will learn the critical distinctions between operating through foreign subsidiaries versus domestic branches and how those choices affect a taxpayer's worldwide tax liability. The program will also highlight the Foreign Derived Deduction Eligible Income (FDDEI) deduction, an appealing alternative that offers domestic corporations a 33.34% tax deduction for specific foreign sales and services. By examining entity classification elections, relevance determinations, and the "Global Intangible Low-Taxed Income" inclusion under Section 951A, attendees will gain the strategic insights necessary to advise clients on the most tax-efficient structures for global operations.
Topics include:
- The impact of Section 951A (NCTI) on U.S. shareholders of Controlled Foreign Corporations (CFCs) and its interaction with existing Subpart F anti-deferral rules
- Eligibility requirements and tax benefits of the FDDEI deduction under Section 250 for domestic corporations engaged in foreign sales and services
- The procedural mechanics and timing requirements for making entity classification elections (Form 8832) for foreign business entities
- Distinguishing between Effectively Connected Income (ECI) and Fixed or Determinable Annual or Periodic (FDAP) income to determine proper U.S. tax filing and withholding obligations
- Tax-planning strategies that compare foreign incorporation with direct domestic operations to optimize deductions and minimize double taxation
Whether advising established closely held businesses or individual clients with foreign investments, you’ll walk away with the knowledge and practical tools needed to confidently help your clients reduce risk and capitalize on opportunities in the global economy.
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