Date: September 11th, 2026

Time: 2pm ET | 1pm CT | 12pm MT | 11am PT

Duration: 150 minutes

Description:

The Tax Cuts and Jobs Act (TCJA) fundamentally reshaped U.S. taxation of foreign business activities by curtailing deferral opportunities and introducing new anti-deferral regimes. This combined webinar delivers a practical, up-to-date review of the modern international tax landscape covering Subpart F income, Net CFC Tested Income (NCTI, formerly GILTI), entity classification, FDDEI planning, and the critical penalty-defense strategies tax professionals need when representing clients before the IRS.

Participants will compare operating through foreign subsidiaries versus domestic branches, evaluate how each structure affects worldwide tax liability, and learn when and how to assert penalty defenses for late or improperly filed international information returns such as FBAR, Form 8938, Form 3520, and Form 3520-A.

Learning Objectives

• Identify how the TCJA changed U.S. taxation of foreign business activities, including anti-deferral rules and the shift from GILTI to Net CFC Tested Income (NCTI).

• Explain Subpart F income and NCTI considerations for foreign corporations, including calculation mechanics and reporting on Form 5471/Form 8992.

• Compare foreign subsidiary and domestic branch structures and their impact on worldwide tax liability.

• Recognize how the FDDEI deduction (formerly FDII) may apply to qualifying foreign sales and services and how recent legislation changed the deduction percentage.

• Analyze entity classification elections (including Section 962) and relevance determinations in international tax planning.
  Evaluate the Section 951A inclusion (NCTI) and its role in structuring global operations.

• Identify international information return penalty defenses relevant to current regulations (e.g., reasonable cause under IRC §6038D).

• Determine the appropriate situations for asserting each penalty defense and summarize key changes in the legal landscape affecting penalty assessments.

• Evaluate strategies to help clients avoid penalties associated with international information returns and minimize exposure during IRS examinations.

Topics Covered

• TCJA Changes to Foreign Business Taxation.

• Subpart F Income and Net CFC Tested Income (NCTI).

• Foreign Subsidiaries vs. Domestic Branches.

• FDDEI Deduction for Foreign Sales and Services.

• Entity Classification and Section 951A Planning.

• International Information Return Penalties and Defenses.

• Practical strategies to reduce penalty risk and navigate abatement requests.

Credits and Other information:

• Recommended CPE credit – 2.5
• Recommended field of study – Taxes
• Session Prerequisites and preparation: None
• Session learning level: Basic
• Location: Virtual/Online
• Delivery method: Group Internet Based
• Attendance Requirement:  Yes
• Session Duration: 150 minutes

Who Will Benefit:

• CPA
• Enrolled Agents (EAs)
• Tax Professionals
• Attorneys
• Other Tax Preparers
• Finance professionals
• Financial planners

About Our Speaker:

Patrick McCormick, JD,LLM

Patrick McCormick is a partner at Culhane Meadows, a national law firm with a prominent international tax practice. He practices exclusively in international taxation, advising foreign businesses with U.S. operations, U.S. businesses with foreign operations, and individual taxpayers with cross-border ties. Patrick routinely collaborates with advisors in the U.S. and abroad to resolve complex international tax planning, structuring, and compliance matters for their clients.

A prolific writer and speaker, Patrick contributes frequently to leading international tax journals, including Tax Notes and the Journal of International Taxation. He is a regular presenter at national seminars and webinars, including recurring sessions with CPA Academy on a range of international tax topics. Patrick holds a J.D. from Vanderbilt University Law School and an LL.M. from New York University School of Law. He is admitted to practice in Pennsylvania, Florida, New Jersey, and Georgia.