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Subpartfinanuteshell denton


Cost Free
Presentation Length 1.5 hours

Recorded DateDecember 5, 2018
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

This course explains the history and operation of subpart F of the Internal Revenue Code. It has been updated to take into account the changes made to these rules by the Tax Cuts and Jobs Act of 2017. Emphasis is placed on the rules for determining whether a corporation is a controlled foreign corporation that is subject to subpart F. This course also covers the types of income and transfers of controlled foreign corporation that may be subject to subpart F.

Note that this is an expanded course. We initially provided a one hour presentation called “Subpart F in a Nutshell (or How Owning a Foreign Company Can Cause Headaches).” Due to audience feedback we have extended that presentation by half an hour. As a warning, this incorporates the original presentation. so, if you watched the last webinar, you will find that 2/3’s of this presentation pretty closely mirrors what you have already seen. We have attempted to incorporate audience feedback and answer some of the generally relevant audience questions that we previously received. We have used much of the additional half hour to more fully explore income and payments that are subject to Subpart F.

Learning Objectives

  • Learn the history and operation of subpart F.

  • Learn to identify a controlled foreign corporation.

  • Learn to identify the types of income and transfers of a controlled foreign corporation that may be subject to subpart F.

Not logged

Sam is an Austin native, a veteran, and a third-generation lawyer. He has tried and won over 15 jury trials in civil court and has worked as an attorney at the Texas Special Prosecution Unit – Civil Division, and as a Legal Assistance Attorney for Texas Military Forces. From 2013 to 2015, while Sam worked as a Legal Assistance Attorney, he ran the tax office, which served all Texas National Guard Soldiers and retirees.

After a short stint as a solo practitioner, Sam and TL Fahring formed “Denton & Fahring, PLLC” in February 2017. Sam’s practice focuses on state and federal tax controversy and litigation.


TL grew up in Anahuac, Texas, a town in Southeast Texas that boasts of having more alligators than people. He obtained his J.D. from the University of Texas School of Law and his LL.M. in Taxation from NYU School of Law. Between UT and NYU, TL clerked for the Texas Eleventh Court of Appeals in Eastland, Texas. After NYU, he worked for around three years as an associate at Meadows, Collier, Reed, Cousins, Crouch, & Ungerman, L.L.P. in Dallas, Texas.

In his free time, TL can be found painting, attending art openings throughout Austin, or running on the hike and bike trail around Lady Bird Lake.

About Our Presenter


Denton & Fahring, PLLC is a boutique general law practice that concentrates on tax controversy and tax litigation at the local, state, and federal levels.

We strive to utilize the latest technologies, up-to-date business techniques, and best practices and efficiencies in order to provide excellent, focused legal representation. We emphasize continuous learning, expertise, and responsive, exceptional client service.