2024 Webinar Series

- 2024 Webinar Series -

Understanding & Modeling Global Tax

Repatriation Planning and APB23

March 12, 2024

Overview

  • Repatriation Analysis – Post TCJA
    – APB23 – Indefinite Reversal Criterion
    – VantagePoint™ Case Study

Learning Objectives

  1. 1. The participants will understand the impact of repatriating foreign earnings in the Post-TCJA environment including IRC Section 245A and accounting for distributions of previously taxed earnings and profits (PTEP).
  2. The participants will have a fundamental understanding of the indefinite reversal criterion of APB23.
  3. The participants will understanding the impact of foreign withholding taxes and other foreign income taxes that may be imposed on dividend distributions.
  4. The participants will understand how foreign exchange gains and losses result from PTEP distributions.
Recording
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Foreign Parented Multinational Groups

April 4,  2024

Overview

This webinar dives into the intricacies affecting foreign parented multinational groups with US operations, including Pillar Two, CAMT, BEAT, US tax reform proposals, and other US tax consequences.

Learning Objectives

  1. Understand the U.S. tax consequences for non-US parented multinational groups, including US sandwich structures.
  2. Understand how Pillar Two rules apply to non-US ultimate parent entities with US operations.
  3. Understand special rules applicable to foreign parented groups for CAMT and BEAT purposes.
  4. Understand Biden administration Greenbook proposals for tax reform affecting foreign parented multinational groups.
Recording
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US Export Incentives: IC-DISC and FDII Optimization

April 11, 2024

Learning Objectives

  1. Understand the history of U.S. Export Tax Incentives from the introduction of Domestic International Sales Corporations (DISC) in 1971 to Foreign Derived Intangible Income (FDII) enacted as part the 2017 Tax Cuts and Jobs Act.
  2. Understand the transformation for DISC to the Interest Charge DISC (IC-DISC) in 1984 and the additional tax savings available to IC-DISC shareholders resulting from the lower tax rates associated with Qualified Dividend Income.
  3. Understand how to maximize IC-DISC tax savings.
  4. Understand the similarities and differences between IC-DISC and FDII tax rules and when the two provisions may be used simultaneously.
Recording
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2023 International Tax Compliance Update

April 18, 2024

Learning Objectives

  1. 1. Understand the U.S. international reporting requirements for U.S. shareholders with foreign operations.
  2. Participants will understand any significant additions or changes to the international tax reporting requirements for the 2023 tax year, including Form 4626 for the Corporate Alternative Minimum tax.
  3. Participants will understand the connection between Form 8975 Country-by-country Report and the Transitional CbCR Safe Harbour for purposes of Pillar Two, including potential traps for the unwary.
Recording
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International Tax Compliance Season Update

July 16, 2024

Learning Objectives

  1. Understand CAMT Guidance including Form 4626 – US and Foreign Based
  2. Form 5471 Reporting Requirements (Worksheet H-1)
  3. CAMT Reporting Requirements for Partnerships
Recording
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Pillar Two – Latest OECD Guidance Issued June 2024

July 16, 2024

Learning Objectives

  1. Understand DTL Recapture
  2. Understand Allocation of Cross-border Taxes (Current & Deferred)
  3. Understand the Allocation of Profits and Taxes, including Flow-through Entities
  4. Understand the Treatment of Securitization Vehicles
Recording
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Pillar Two Update: GloBE Information Return

September 12, 2024

Learning Objectives

  1. Participants will receive a Pillar Two Legislative Update
  2. Participants will understand the status of the GloBE Information Return (GIR) and anticipated Filing Requirements
  3. Participants will be provided a detailed analysis of the GIR, including:
    – Jurisdictional Safe Harbours and Exclusions
    – GloBE Computations including Jurisdictional Sub-Groups
    – The impact of Cross-border tax allocations and special entity classifications
Recording
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Modeling the Future & Pillar Two

November 19, 2024

Learning Objectives

  1.  Participants will receive an update of recent administrative guidance provided by the OECD and EU.
  2. Participants will be briefed on anticipated tax legislative goals considering the US elections.
  3. Participants will receive guidance related to US international tax modeling and repatriation analysis.
  4. Participants will understand the interplay between US tax calculations and Pillar Two.
  5. Participants will understand the status of the GloBE Information Return.
Recording
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