Simplified 951A part 1: Basics
Channel: International Tax
Date: 2019-05-16

951A Inclusions - Part 1 - Basics
US shareholders of CFCs must include in their income their share of all CFCs' incomes in excess of 10% return on assets.  This video covers the basic rules, what's excluded, and calculating the inclusion.  3 other videos cover other aspects.  Here's what's in the video:
00:00  Intro & overview
01:08  Context: new §§245A, 250, 951A
01:21  Super simple example
02:24  More on 245A, 250
03:39  Basic rule, again
04:18  US shareholder & CFC
05:20  Example chart
05:43  Attribution
06:00  Calculating the inclusion:  steps
07:29  What gets excluded
09:08  Deductions; allocation & apportionment
11:35  Coming up in video 2:  10% RoA, pro rata share, aggregation


Here are links to the law and proposed regulations:
Law:  26 USC 951
Proposed regs:  Reg. –104390 –18  IRB 18-43 beginning on the eighth page.