2022 Webinar Series

- 2022 Webinar Series -

Understanding & Modeling Global Tax

Session 1

FTC Regulations Part I

Mon, Feb 7, 2022

During this webinar our panel will walk participants through the key elements of the Final January 4, 2022 FTC regulations, both by an analysis of the regulation examples, as well as the practical implementation issues.

Learning Objectives:

Participants will gain understanding of the following:
– The net gain requirements
– Attribution vs. Jurisdictional Nexus
– In-lieu-of income tax requirements
– Treas. Reg. 1.861-20 allocation of income taxes

Session 2

FTC Regulations Part II

Tue, Feb 15, 2022

During this webinar our panel will walk participants through the key elements of the Final January 4, 2022 FTC regulations, both by an analysis of the regulation examples, as well as the practical implementation issues.

Learning Objectives:

Participants will gain understanding of the following:
  – The net gain requirements
  – Attribution vs. Jurisdictional Nexus
  – In-lieu-of income tax requirements
  – Treas. Reg. 1.861-20 allocation of income taxes

Session 3

International Tax Update K-2/K-3

Tue, May 31, 2022

Beginning for 2021 tax years, new schedules K-2 and K-3 standardize and very significantly expand the international tax reporting requirements for pass-through entities. Participants in this webinar should gain a general understanding of the data elements included in the schedules and the mechanics behind completing the schedules.

Learning Objectives:

Participants will gain understanding of the following:
– What information is required to complete Schedules K-2 and K-3
– Who is required to files Schedules K-2 and K-3
– When Schedules K-2 and K-3 must be filed

Session 4

The ABC’s of Fully Integrated International Tax Modeling 

Wed, Aug 3, 2022

Learning Objectives:

1. The participants will understand several essential international tax modeling concepts relevant throughout the planning, provision, and compliance tax department lifecycle.
2. The participants will receive statutory and administrative citations to support the calculations demonstrated during the webinar.

Webinar Description

This session provides an interactive guide to essential international tax modeling scenarios using Forte’s VantagePoint™ software as the quantitative tool. The panelists will demonstrate specific examples throughout the planning, provision, and compliance lifecycle. The demonstration begins with international tax compliance and the resulting tax attributes and sourcing which serve as the foundation for all future modeling. Tax technical citations for the underlying calculations are provided and the Webinar provides one-hour of CPE credit.

Listed below are some of the modeling scenarios demonstrated during the Webinar.

A – Optimizing International Tax Compliance Calculations
• 163(j) CFC Group election
• GILTI High-tax Exclusion election
• Treas. Reg. 1.861-8 Methodology
B – 2022 Tax Provision
• Interim Quarters/Forecast vs. Year-End
• Historical Tax Attributes
• APB23 Roll-Up Calculations
C – Global Tax Planning
• Repatriation Analysis
• Transfer Pricing Analysis
• GloBE meets GILTI

Session 5

Foreign Tax Credit Regulations (as corrected) Plus: New Book Minimum Tax AMT FTC

Wed, Aug 31, 2022

Learning Objectives:

1. The participants will understand the specific requirements, as prescribed by the latest updates to the foreign tax credit regulations, in order to be able to obtain a foreign tax credit for foreign taxes paid or accrued.
2. The participants will understand the rules for allocating and apportioning foreign income taxes between the various operative sections of the internal revenue code.
3. The participants will understand the specific reporting requirements for foreign taxes paid or accrued associated with various IRS forms, including Form 5471 and 1118, for the 2021 income tax year.

Webinar Description

Listed below is an overview of the topics discussed in this webinar.

A – Creditability Matters
• Attribution Rule
• Net Gain Requirement
• Latest Administrative Guidance
B – Allocation and Apportionment
• DRE and CFC Regulations
• U.S. Shareholder Level Calculations
C – Reporting Requirements
• Form 1118
• Form 5471, including Schedule E and J
• Other

 

Session 6

GloBE Meets GILTI – Pillar Two Update

Wed, Oct 19, 2022

Overview

Latest OECD Guidance and Timeline
European Union and Other Countries’ Perspectives
US Landscape
Practical Modeling Solutions

Learning Objectives

The participants will understand the latest OECD Pillar II Guidance including potential implementation timelines.
The participants will understand the status of the EU’s acceptance of Pillar II.
The participants will understand how various US international tax rules interplay with Pillar II, including the allocation of income taxes, and their impact on potential modeling scenarios.

 

Session 7

Repatriation & the APB23 Assertion

Wed, Nov 16, 2022

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

Learning Objectives:

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.

Session 8

VANTAGEPOINT™ Integrated Modeling Demonstration

Explore GILTI, FDII, FTC, and Pillar Two

Fri, Dec 9, 202

Are you looking for a nimble solution with more control to perform your international tax planning and calculations? VantagePoint™ is the only fully integrated FTC/GILTI/FDII application supporting planning, provision, and compliance requirements.  The software is constantly updated with the latest regulations and is multi-year, simplifying amending returns and historical tax attribute tracking.

We are pleased to invite you to this specially scheduled interactive forum, where you can take a closer look at our VanatgePoint application to see if it would benefit your Company as a consulting tool or software license

We work with clients on a consulting, co-sourcing and license basis and want to support you in providing value to your Company in both process efficiencies and tax savings.  We work with large multinational firms (Fortune 250), just like yours, from a range of industries and simple to very complex tax structures.

Please send any specific questions ahead of the webinar to Allison Lavigne and we will answer them during the session as time allows or follow up offline.