2024 Global Tax Optimization Boot Camp

Global Tax Optimization Boot Camp

4 MOdules focused on moving the needle
Please email if you would like to receive information about the recorded online Boot Camp or future learning events.


Up to 6 Hours of CPE over Two Days

Technical Sessions
Tuesday, March 26 & Thursday, March 28
10:00 - 11:30 am and 2:00 - 3:30 pm CST

CPE CREDITS: Up to 6 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
Mark Gasbarra
David Merrick
Baker Tilly
Alexis Bergman
MCdermott, Will, Emery
John Karasek
Phil Laminack
Dave Macall



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



Pillar Two and U.S. Tax Interplay


Subpart F, GILTI and High-Tax Income Elections



Treas. Reg. 1.861-8, FDII and Foreign Tax Credit


163(j), BEAT and CAMT


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.


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.


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.


Early Bird Registration for LIVE ONLINE WORKSHOP is open until March 1st.

Registration will close after March 25th.  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 two (2) 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.

Single Session Registration

Delivery Methods

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

The program is delivered through 4 distinct but interrelated topical sessions.  Each of the 4 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.


International Tax Experience

Program Level


Advance Preparation



All options include the same access to each of the Technical Sessions modules.

Single Registration

This registration option is for single participants.

Group Registration

This registration option is for groups of 2 or more participants. This is our flat rate option, which includes unlimited attendees from the same Company.

Preliminary Program

Technical Sessions

Tuesday, March  26

10:00 AM – 11:30 AM CST

Module 1: Pillar Two and U.S. Tax Interplay

  • Pillar Two Legislative Update
    • Highlights by Region
  • IRS Notice 2023-80 – Technical Overview
    • QDMTT vs. Final Top-up Tax
  • VantagePoint – Case Study Introduction
  • Transitional Safe Harbour
  • Pillar Two Report
  • QDMTT Allocation Keys
  • Top-up Tax Report

Learning Objectives

  1. Understand the current state of Pillar Two Legislation
  2. Understand the interplay between Pillar Two and U.S. Tax Calculations

2:00 PM – 3:30 PM CST

Module 2: Subpart F, GILTI and High-Tax Income Elections

  • Foreign Earnings and Profits (E&P) vs. Tested Income
  • Allocation and Apportionment of Income Taxes
  • S. Subpart F Analysis
    • De minimis, Full Inclusion
    • High-tax Exception Election
    • Section 952(c) E&P Limitation
  • GILTI High-tax Exclusion Election
  • Pillar Two U.S. Tax Interplay

Learning Objectives

  1. Understand how to compute foreign earnings and profits and tested income.
  2. Understand the differences between subpart F and global intangible low-taxed income (GILTI).
  3. Understand when and How to elect the Subpart F high-tax income exception and the and GILT High-tax Exclusion and their impact on Pillar Two Top-up Taxes

Thursday,  March 28

10:00 AM – 11:30 AM CST

Module 3: Treas. Reg. 1.861-8, FDII and Foreign Tax Credit

  • Reg. 861 – Analysis
    • Interest Expense and Steward
    • Research and Experimental
    • Other Deductions
  • FDII Analysis and Optimization
  • Foreign Tax Credit Analysis and Optimization

Learning Objectives

  1. Gain a detailed understanding of Treas. Reg. Section 1.861-8 and its impact on FDII and the U.S. Foreign tax Credit.
  2. Understand how to Analyze and Optimize the Foreign Derived Intangible Income (FDII) Deduction.
  3. Understand how to Analyze and Optimize the U.S. Foreign Tax Credit Limitation.

2:00 PM – 3:30 PM CST

Module 4: 163(j), BEAT and CAMT

  • Section 163(j) and CFC Group Election
  • Base Erosion and Anti-Abuse Tax (BEAT)
  • Corporate Alternative Minimum Tax (CAMT)
  • Foreign Parented MNE Groups

Learning Objectives

  1. Understand the Section 163(j) limitation on the deductiblity of interest expense.
  2. Understand the mechanics of the 163(j) CFC Group election.
  3. Understand the computation of the Corporate Alternative Minimum Tax (CAMT), the CAMT FTC and the special rules for Foreign Parented Multinational Groups.


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.

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.