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International Tax: Outbound Structuring after GILTI High-Tax Regulations


Cost Free
Presentation Length 1.5 hours

Recorded DateJuly 23, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelIntermediate
Course Description

This webinar will introduce the methods used by the United States to tax foreign-sourced income earned by foreign corporations with American stakeholders. 

The United States institutes a multitude of anti-deferral mechanisms targeting this income. The 2017 GILTI regime initially created a seismic shift in how foreign corporate activities are taxed; in July 2020, GILTI regulations were released, further altering decision making. 

This program will focus on the anti-deferral provisions relevant for foreign corporations’ stakeholders – with particular emphasis on how GILTI alters deferral opportunities previously available and how the high-tax exclusion contained in the regulations significantly modifies GILTI's scope. Options for GILTI mitigation will also be covered – both methods for reducing GILTI’s tax effect and alternate possibilities for generating foreign-sourced income.

Learning Objectives: 

  • Identify the methods used by the United States to tax foreign-sourced income earned by foreign corporations with American stakeholders

  • List the anti-deferral provisions  relevant to foreign corporations’ stakeholders

  • Recognize how GILTI regulations altered decision-making

  • Determine the methods used for GILTI mitigation

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Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick practices exclusively in the area of international taxation. He has extensive experience handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with their clients’ international tax issues.

Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with on various international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law.  His bar admissions include Pennsylvania, Florida, New Jersey, and Georgia.

Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication named Patrick Estate Planning Lawyer of the Year (United States) for 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.


About Our Presenter

Culhane Meadows is proudly shaking up the legal marketplace by offering exceptional, yet highly-efficient and cost-effective, client services provided exclusively by partner-level attorneys with substantial experience from large law firms or in-house legal departments of respected corporations.