Program Details
2026-10-27 14:30:00
Over 1,000+ webinars
Course Overview
2026-10-27 14:30:00
2h CLE Credits
Intermediate
2
2:30 pm - 2:50 pm ESTThis session establishes the definitional foundation, examining what makes a foreign corporation a CFC and which owners qualify as U.S. shareholders, the threshold classifications on which every later planning decision depends.
Christopher M. KlugGina Jeyoung Lee 2:50 pm - 3:10 pm ESTAttention then turns to the operative regimes, exploring how Subpart F and GILTI/NCTI reach CFC earnings and shape the annual burden carried while ownership continues.
Christopher M. KlugGina Jeyoung Lee 3:10 pm - 3:30 pm ESTSpeakers next unpack previously taxed earnings and profits, tracing how PTEP accounts arise, why careful tracking matters when distributions occur, and the corresponding basis adjustments that accompany them.
Christopher M. KlugGina Jeyoung Lee 3:40 pm - 4:00 pm ESTDiscussion then shifts to IRC section 1248, addressing when gain on a disposition of CFC stock is recharacterized as a dividend and what that treatment means for the selling shareholder.
Christopher M. KlugGina Jeyoung Lee 4:00 pm - 4:20 pm ESTBuilding on the dividend theme, this segment considers the IRC section 245A dividend received deduction, where it fits within the planning, and how its availability influences the structures chosen.
Christopher M. KlugGina Jeyoung Lee 4:20 pm - 4:40 pm ESTThe program closes by weighing the exit routes against one another, from elections and taxable liquidations through Section 332, 367(b), stock sales, Section 338, and foreign to foreign restructurings.
Christopher M. KlugGina Jeyoung LeeChristopher M. Klug is a Partner and Co-Founder of Basswood Counsel (formerly Klug Counsel PLLC), an international tax planning attorney who represents businesses and individuals in domestic and international taxation, tax controversy, corporate and business planning, mergers and acquisitions, cross-border transactions, domestic and international estate planning, and trust administration. Drawing on decades of practice that pairs large-firm training with a hands-on boutique approach, he works alongside each client’s financial advisors, accountants, and leadership team so that tax strategy aligns with the client’s larger goals.
Gina Jeyoung Lee is a partner and co-founder of Basswood Counsel and a tax and estate planning advisor with extensive experience in U.S. tax law and tax treaties. She provides strategic counsel on individual and business tax planning, compliance, and controversies, along with domestic and international estate planning, and has been instrumental in helping clients with new business entity formation and fund formation while keeping them compliant with corporate regulatory requirements. She is known for understanding each client’s circumstances and tailoring her advice to their needs.
Christopher M. Klug is a Partner and Co-Founder of Basswood Counsel (formerly Klug Counsel PLLC), an international tax planning attorney who represents businesses and individuals in domestic and international taxation, tax controversy, corporate and business planning, mergers and acquisitions, cross-border transactions, domestic and international estate planning, and trust administration. Drawing on decades of practice that pairs large-firm training with a hands-on boutique approach, he works alongside each client’s financial advisors, accountants, and leadership team so that tax strategy aligns with the client’s larger goals.
Gina Jeyoung Lee is a partner and co-founder of Basswood Counsel and a tax and estate planning advisor with extensive experience in U.S. tax law and tax treaties. She provides strategic counsel on individual and business tax planning, compliance, and controversies, along with domestic and international estate planning, and has been instrumental in helping clients with new business entity formation and fund formation while keeping them compliant with corporate regulatory requirements. She is known for understanding each client’s circumstances and tailoring her advice to their needs.
Requirements
The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.
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