– 2020 Fall Webinar Series –
Understanding & Modeling Global Tax
Session 1
GILTI High Tax Exclusion
Agenda
Mechanics of the calculation
Tested Units
Effective Tax Rate
Impact of Disregarded transactions
Interplay with other international tax provisions
Section 163(j)
Foreign Tax Credit
BEAT
Integrated Case Study Example
Including 1.861-8 Apportionment
Presented by:
Forte International Tax, LLC
Mark Gasbarra, National Managing Director
Jefferey Prescott, Manager
Session 2
CARES Act
Agenda
NOL Carryback and related provisions
Interplay between NOL, Section 965, GILTI, FDII, FTC and BEAT
Expanded Section 163(j) options for 2019 and 2020 tax years
Impact on the GILTI High-tax Exclusion and other elections
VantagePoint Case Study
Presented by:
Mark Gasbarra, Forte International Tax, National Managing Director
Alexis Bergman, CPA, True Partners Consulting, Director of International Services
Session 3
Repatriation Analysis, PTEP, Tax Basis
Agenda
Repatriation analysis
TASC 740 income tax provision
Treatment of additional taxes paid on PTEP distributions and the Excess Limitation Account
Characterization of CFC Stock under Treas. Reg. ยง 1.861-13 for apportioning Interest expense and stewardship
Impact of the GILTI High-Tax Exclusion
Presented by:
Forte International Tax, LLC
Mark Gasbarra, National Managing Director
Lester Fuwa, Managing Director
Marilyn Jankowski, Director
Scott Bozzi, International Tax Consultant
BKD LLP
Chris Clifton, Managing Director