News & Events

April 22, 2019

CFC Tax Planning for Individuals and Family Offices An Update

Paul Marcotte, Tax Chair

Paul Marcotte was a panelist for a seminar titled “CFC Tax Planning for Individuals and Family Offices An Update” on Thursday, April 25, 2019 at 12:30 pm. The event was organized by STEP Mid Atlantic.

There was a luncheon immediately preceding the presentation, which was held at Paley Rothman, 4800 Hampden Lane, 6th Floor, Bethesda, MD 20814. 

Program topics included:

  • Review TCJA International Modifications
  • Transition Tax Issues
  • Downward Attribution
  • GILTI
  • The pros and cons of strategies for U.S. Shareholders to Restructure CFC participations
  • Individual Ownership
  • Corporate Ownership
  • Section 962 Election
  • Check-the-Box Election
  • Repatriation of PTEP and FTC Planning
  • An Alternative: Foreign Derived Intangible Income
  • Section 956
  • Q&A

Paul Marcotte Chairs the firm’s Tax practice group and is a member of its Estate Planning, Estate & Trust Administration and Nonprofit groups. 

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