2023 Pillar Two Boot Camp

SPECIAL EDITION
Pillar Two Boot Camp

RECORDING AVAILABLE
Please email if you would like to receive information about the recorded online Boot Camp or future learning events.

PREPARING INTERNATIONAL TAX PROFESSIONALS
FOR PLANNING, PROVISION, AND COMPLIANCE

Up to 14 Hours of CPE over Two Weeks

Technical Sessions - Up to 9 CPE
November 27th - December 1st
Monday, Wednesday, Friday Sessions
10:00 - 11:30 am and 2:00 - 3:30 pm CST
+
INTERACTIVE Case Study - Up to 5 CPE
December 4th - 8th
Monday - Friday Sessions
10:00 - 11:00 CST

CPE CREDITS: Up to 14 CPE credits in the Taxes field of study may be awarded upon verification of participant attendance.

NASBA Field of Study: Taxes

Level: Intermediate

Delivery Method: Group Internet Based

Program Faculty
FORTE
Mark Gasbarra
David Merrick
Baker Tilly
Alexis Bergman
MCdermott, Will, Emery
John Karasek
Forvis
Justin Metcalfe
Phil Laminack
Dave Macall
Ashton Castagna
Brooke Simpson
Eric Flueckiger

LEARNING MODULES

TWELVE ENGAGING LEARNING MODULES ILLUSTRATE THE POWER OF INTEGRATED INTERNATIONAL TAX PLANNING, PROVISION, AND COMPLIANCE

All Modules include:
Technical Overview
Integrated Case Study
International Tax Forms

MONDAY, NOV 27

MODULE I

OECD Guidance and Legislative Update

MODULE II

Top-Up Tax and Tax Accounting

WEDNESDAY, NOV 29

MODULE III

Charging
Provisions

MODULE IV

Pillar Two Safe Harbours and Elections

FRIDAY, DEC 1

MODULE V

Interplay with U.S. Tax Calculations

MODULE VI

GloBE Information Return

+CASE
STUDY

OPPORTUNITY FOR PRACTICAL APPLICATION OF PILLAR TWO CONCEPTS

MONDAY
DEC 4

SESSION 1

Introduction

Financial Accounting Net Income or Loss

TUESDAY
DEC 5

SESSION 2

Tax Purposes

Adjustments

Country-by-Country Report

WEDNESDAY
DEC 6

SESSION 3

U.S. Tax Calculation

Pillar Two Reports

THURSDAY
DEC 7

SESSION 4

GloBE Information Return

FRIDAY
DEC 8

SESSION 5

Wrap-Up

Review Results

Q&A

WEEK 1

In the first week, Technical Sessions will run twice a day on Monday, Wednesday and Friday with the ability to earn up to 9 hours of CPE.  An integrated Case Study will be presented alongside the technical content to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.

WEEK 2

In the second week, participants will have the option of earning an additional 5 hours of CPE during a series of interactive Case Study development sessions using VantagePoint as a modeling tool.  This session focuses on a step-by-step methodology to implementing Pillar Two and integrating its operational rules along with other U.S. international tax calculations and compliance requirements.

Highlights include...

Latest International Tax Technical Content

  • Practical, immediately useful knowledge, keeps you you up-to-date on the latest U.S. outbound international tax compliance requirements.
  • Insightful tax saving strategies. 
  • Highly skilled instructors with decades of client-serving experience. 
  • Learning objectives are reinforced through integrated Case Study examples.

LEARNING OBJECTIVES

This workshop is designed to keep international tax professionals up to date with the latest provision and compliance requirements and the impact of proposed global tax initiatives, with a focus on Pillar Two.  As a result of active participation, program recipients will be able to meet the following learning objectives:

  • Participants will understand OECD Guidance and the global state of Pillar Two legislation.
  • Participants will understand Pillar Two Operational Rules.
  • Participants will understand key GloBE income and tax adjustments.
  • Participants will understand Pillar Two Safe Harbours and elections.
  • Participants will understand how to complete the GloBE Information Return.

REGISTRATION

Early Bird Registration for LIVE ONLINE WORKSHOP is open until October 20th.

Registration will close November 20th.  Please reach out by email if you are unable to make that deadline.

 

You may register for a single registration or join us as a business group.  If you have more than one colleague joining from your Company, we invite you to take advantage of the discounted “Add-on Registration” option.  If you have more than nine (9) representatives from the same company, we invite you to choose the “Group Rate” for unlimited registration by Company.  If you choose the add on or group option, please email the registrants names.

Please email if you would like to receive information about the recorded online Boot Camp or future learning events.

Delivery Methods

This is an online workshop with live interaction with highly skilled and experienced program instructors. 

The program is delivered through 11 distinct but interrelated topical sessions.  Each of the 11 sessions includes an overview of the latest international tax technical content, numerical examples explaining the underlying computational requirements, and how to report the computational results on the related tax forms. 

A comprehensive case study is used to integrate the individual learning objectives.

Refunds are accepted for duplicative registration only. CPE Policies

Prerequisites

International Tax Experience

Program Level

Intermediate

Advance Preparation

None, however, intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Whole Series Registration

Single Session Registration

REGISTRATION OPTIONS

All options include the same access to RECORDINGS of each of the Technical Sessions modules and access to the Interactive VantagePoint Case Study Bonus sessions.  Note since these are recordings there is no CPE available at this time.

Single Registration

This registration option is for single participants.  Choose this option if you are the only registrant or the first registrant in your Company.

Add On Registration

Combined with the single registration, we offer a discount for additional registrations per Company. Add up to 8 additional participants with the “Add On” option.

Group Registration

This registration option is for groups of 9 or more participants. This is our flat rate option, which includes unlimited attendees from the same Company.

Preliminary Program

Technical Sessions - Modules I-VI

WEEK 1

Monday, November  27

10:00 AM – 11:30 AM CST

Module I: OECD Guidance and Legislative Update

  • Overview of OECD Guidance
  • Jurisdictional Update
  • Subject to Tax Rule (STTR)

2:00 PM – 3:30 PM CST

Module II: Top-Up Tax and Tax Accounting

  • Operational Rules
  • GloBE Income Adjustments
  • Tax Adjustments

Wednesday,  November 29

10:00 AM – 11:30 AM CST

  • Module III: Charging Provisions
  • Qualified Domestic Top-up Tax (QDMTT)
  • Income Inclusion Rule (IIR)
  • Under Taxed Profit Rule (UTPR)

2:00 PM – 3:30 PM CST

Module IV: Pillar Two Safe Harbours and Elections

  • Safe Harbours
  • Elections
  • Penalty Relief

Friday,  December 1 

10:00 AM – 11:30 AM CST

Module V: Interplay with U.S. Tax Calculations

  • U.S. Ultimate Parent Entity (UPE)
  • Foreign UPE with U.S. Sandwich Structure
  • UPTR Safe Harbour
  • Corporate Alternative Minimum Tax (CAMT)

2:00 PM – 3:30 PM CST

Module VI: GloBE  Information Return

  • Coordination Pillar Two Operational Rules
  • Simplified Filing Requirements
  • Surrogate Entity Jurisdiction

CASE STUDY - SESSIONS 1-5

WEEK 2

Monday, December  4th

10:00 AM – 11:00 AM CST

Session 1: Case Study Introduction and Financial Accounting Net Income or Loss

  • Legal Structure
  • Jurisdictional Tax Attributes
  • Financial Accounting Net Income or Loss (FANIL)
  • Chart-of-Accounts
  • Trial Balances

Tuesday, December 5th

10:00 AM – 11:00 AM CST

Session 2: Tax Purposes, Adjustments and Country-by-Country Report

  • Tax Purposes
  • Adjustments
  • Country-by-Country Report
  • IRS Form 8975

Wednesday, December  6th

10:00 AM – 11:00 AM CST

Session 3: U.S. Tax Calculations and Pillar Two Reports

  • Operational Rules
  • GILTI, FDII and FTC
  • Transitional Safe Harbour Report
  • Pillar Two Report

Thursday, December  7th

10:00 AM – 11:00 AM CST

Session 4:  GloBE Information Return

  • MNE Group Information
  • Jurisdictional Safe Harbours and Exclusions
  • GloBE Computations

Wednesday, December  8th

10:00 AM – 11:00 AM CST

Session 5: Wrap Up, Review Results and Q&A

  • Jurisdictional Attributes
  • FANIL and Adjustments
  • S. Tax Calculations
  • Pillar Two Reports
  • GloBE Computations
  •  

Questions?

For additional information, including regarding program refund or cancellation policies or CPE, contact Forte or complete the form below.  Click here to read the CPE FAQ.

Email

Forte International Tax, LLC is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.