With hat being said, there are complex new CFC rules in place by the U.S. government pose unique international tax challenges to U.S. persons with non-U.S. businesses and investments. First, Brunoro-Borokhov spoke on specific methods of domesticating and restructuring foreign corporations to mitigate an increase in tax liability and provide tax savings. Lastly, U.S. taxpayers affected by this change, as well as tax professionals and advisors, must reexamine existing structures of foreign corporations under their purview.
The panel discussed these and other key issues:
• How does tax reform impact rules governing U.S. persons with non-U.S. businesses and investments?
• What factors must be considered by non-corporate U.S. shareholders of foreign corporations?
• What methods are available for domesticating or restructuring CFCs for U.S. taxpayers?
• How can Section 962 elections ensure tax savings?
• Application of the transition tax and GILTI for purposes of domesticating of a foreign corporation
About Brunoro Law, APC
Paula Brunoro-Borokhov is the principal attorney at Brunoro Law, APC, a leading international tax law firm located in San Diego California. She received her J.D. equivalent from the Faculdade de Direito de Vitória in Brazil, graduating Summa Cum Laude. She obtained her LL.M degree in Business and Corporate Law from the University of San Diego. Furthermore, her LL.M in Taxation from the New York University School of Law. Moreover, she has been recognized by both the San Diego Daily Transcript and San Diego Business Journal for her legal accomplishments and is an active member of the California Lawyers Association.
To conclude, Brunoro Law specializes in assisting businesses and individuals with business and tax-related matters. The firm’s practice areas include but are not limited to: Tax Controversy, Collections, Planning, International Tax, and Corporate law with a specialization in representing clients in cross-border transactions. Contact the firm to receive more information or request a consultation from Paula Brunoro.