- 2020 Fall Webinar Series -

Understanding & Modeling Global Tax

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

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

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. § 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