Net CFC Tested Income (Formerly GILTI) and Form 5471 Reporting  

This course discusses Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, including an analysis of the various filing categories associated with the form and the filing requirements associated with those categories. In addition, the course discusses the primary concepts of the Net Controlled Foreign Corporation (CFC) Tested Income (NCTI) calculation. The course will also cover the information reported in Schedule C (Income Statement) and Schedule F (Balance Sheet) of Form 5471, as well as an overview of the relevant U.S. tax issues, such as earnings and profits and Subpart F rules. The course will look at Form 5471 reporting associated with the income and expense items (e.g., NCTI, earnings and profits, and Subpart F). Lastly, the course will look at other information and reporting items that are included in Form 5471, including transactions affecting the ownership of the foreign corporation and related-party transactions. This advanced-level course focuses on the development and expansion of in-depth knowledge, skill, and application of global intangible low-taxed income.