7th Annual
International Tax Boot Camp
10 Modules focused International Tax
PREPARING INTERNATIONAL TAX PROFESSIONALS
FOR PLANNING, PROVISION, AND COMPLIANCE
Up to 15 Hours of CPE over Five Days
Technical Sessions
June 1 - 5, 2026
10:00 am - 11:30 pm and 1:00 pm - 2:30 pm CST
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CPE CREDITS: Up to 15 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
Wendy McDonald
Scott Bozzi
Velia Flores
Forvis
Justin Metcalfe
Phil Laminack
Chris Clifton
Eric Flueckiger
LEARNING MODULES
June 1 – 5, 2026
10:00 am – 11:30 am &
1:00 pm – 2:30 pm CST
FIFTEEN 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, JUNE 1
MODULE I
Introduction & OB3 Overview
MODULE II
Pillar Two
TUESDAY, JUNE 2
MODULE III
Subpart F / GILTI / NCTI
MODULE IV
163(j) / 1.861-8
WEDNESDAY, JUNE 3
MODULE V
FDDEI / 1.861-8
MODULE VI
FTC / 1.861-8
THURSDAY, JUNE 4
MODULE VII
BEAT / CAMT
MODULE VIII
Repatriation, 987, APB23
FRIDAY, JUNE 5
MODULE IX
Recent IRS Guidance
MODULE X
International Tax Compliance
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,
- 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:
- Impact of OB3 on 2025 tax years, 2026 and beyond, especially as it relates to FDDEI and Net CFC Tested Income.
- Understand Pillar Two State of Play including immediate compliance requirements and the Side-by-Side Agreement.
- Understand foreign E&P, Subpart F, NCTI and the impact on U.S. shareholders.
- Explore a deep dive into the Allocation and Apportionment Rules under Treas. Reg. 1.861-8 and their impact n all U.S. international tax calculations.
- Participants will understand the detailed requirements in determining the Section 250 FDDEI deduction.
- Gain a detailed understanding of the limiting factors impacting the U.S. foreign tax credit including the impact of the Overall Foreign Loss rules.
- Understand the Section 163(j) limitations on the deduction of interest expense on both U.S. and foreign operations.
- Understand the U.S. minimum tax provisions including BEAT and the CAMT.
- Understand the impact of recent international tax guidance released by the IRS, including the impact on CAMT and the determination Section 987 gains and losses.
- Keep up to date on the latest international tax compliance requirements.
REGISTRATION
Early Bird Registration for LIVE ONLINE WORKSHOP is open until May 1st.
Registration will close after May 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 five (5) 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.
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 10 distinct but interrelated topical sessions. Each of the 10 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.
Prerequisites
International Tax Experience
Program Level
Intermediate
Advance Preparation
None
REGISTRATION OPTIONS
All options include the same access to each of the Technical Sessions modules.
Single Registration
This registration option is for single participants or the first (required) registration of corporate groups of four or less in combination with the “Add On” Registration.
ADD ON Registration
This registration option is for corporate groups of 3 or less participants. One single registration is required and the Add On rate can be used for up to three more attendees from the same company.
Group Registration
This registration option is for groups of 4 or more participants. This is our flat rate option, which allows for unlimited attendees from the same Company.
Preliminary Program
Technical Sessions
Detailed agenda pending. Please check back soon.
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
- Understand the current state of Pillar Two Legislation
- 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
- Understand how to compute foreign earnings and profits and tested income.
- Understand the differences between subpart F and global intangible low-taxed income (GILTI).
- 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
- Gain a detailed understanding of Treas. Reg. Section 1.861-8 and its impact on FDII and the U.S. Foreign tax Credit.
- Understand how to Analyze and Optimize the Foreign Derived Intangible Income (FDII) Deduction.
- 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
- Understand the Section 163(j) limitation on the deductiblity of interest expense.
- Understand the mechanics of the 163(j) CFC Group election.
- Understand the computation of the Corporate Alternative Minimum Tax (CAMT), the CAMT FTC and the special rules for Foreign Parented Multinational Groups.
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.
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.