International Tax Lunch: Guide to Global Intangible Low-Taxed Income (Section 951A) Webcast | 4193821A

Date :
September 13, 2019 12:00 PM - 1:00 PM
Location :
Facility :
Webcast Remote
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Member Price :
Nonmember Price :
CPE Credits :
CPE 1.00, MCLE 1.00, IRS-TX 1.00, MCLE LS-TX 1.00
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U.S. shareholders of foreign corporations have a new pass-through income category to contend with: GILTI. Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders.

This session explores the new rules. What is GILTI? How will it affect U.S. shareholders? What countermeasures are available? 


  • Understand what types of income will be characterized as GILTI.
  • Explore the interaction of GILTI's income recognition rules and the dividend received deduction rules.
  • Review the application of the foreign tax credit rules.
  • Examine different holding structures available to U.S. shareholders, and the effect of holding structure choice on the shareholders' tax liability. 

Major Subjects:

  • GILTI and new Section 951A.
  • Dividend received deductions.
  • Foreign tax credit.

Advanced Prep:


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Designed For:

Lawyers and CPAs.


Philip D.W. Hodgen, Esq, Esq.

Philip D. W. Hodgen is the principal attorney for HodgenLaw PC, which specializes in the international tax arena. He earned his bachelor’s degree from Claremont McKenna College and his juris doctor degree from the School of Law at the University of California, Los Angeles. He went on to earn a master of laws in taxation from the University of San Diego School of Law. For six years as a youth, he lived in Rhodesia, South Africa and New Zealand.

Admitted to the California Bar in 1982, Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. He is a past chair of the International Tax Committee of the State Bar of California’s Tax Section, and was a member of the Executive Committee of the State Bar of California’s Tax Section from 2004-07. He is on the Organizing Committee for CalCPA’s International Tax Conference and its annual Tax Update and Planning Conference. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, bankers, and real estate professionals.

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