Topics of discussion will include the structuring ramifications complying with the repeal of Code Section 958(b)( 4 ), preparation as well as structuring considerations for the abolition of the "thirty days regulation" for CFC's, the proposed PFIC guidelines, as well as the GILTI guidelines as well as the new "high tax exemption." Panelists will certainly likewise review the resurrection of Code Area 962, the suggested foreign tax obligation credit regulations, message purchase tax problems, assistance for Code Area 965, as well as suggested guidelines for Code Section 267(a).