2025 Webinar Series

- 2025 Webinar Series -

Understanding & Modeling Global Tax

Pillar Two Update: Cross Border Tax Allocations 

January 23, 2025

Learning Objectives

  1. Obtain a general understanding of the OECD’s guidance on the Allocation of Cross-border Taxes and its impact on Covered Taxes for Pillar Two purposes.
  2.  Understand the relationship between the Allocation of Cross-border Current Taxes and the temporary treatment for Blended CFC Regimes like GILTI.
  3. Understand the Four-Step Method for Allocating Cross-border Current Taxes.
  4. Understand the treatment of Main Entities and their subsidiaries, and special treatment afforded to tax transparent entities.
Recording
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Export Incentives: Part 1 Overview

January 30,  2025

Learning Objectives

  1. Participants will understand the History of U.S. Export Tax Incentives.
  2. Participants will understand the tax saving opportunities associated with IC-DISCs and the deduction for Foreign Derived Intangible Income (FDII).
  3. Participants will understand the consistency requirements under Treas. Reg. 1.861-8.
  4. Participants will understand how IRC Section 864 and the 1.861-8 Treasury Regulations impact the benefits associated with IC-DISC and FDII.

  5. Participants will understand the specific requirements for apportioning Interest Expense, Stewardship, R&D and other deductions for IC-DISC, FDII and other Operative Sections of the Internal Revenue Code.

Recording
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Export Incentives: Part 2a FDII Breakout

January 30,  2025

Overview

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Learning Objectives

  1. Participants will understand the qualification requirements for the Foreign Derived Intangible Income (FDII) deduction.
  2. Participants will understand how to calculate the FDII deductions.
  3. Participants will understand the interplay between FDII,GILTI, FTC and Section 163(j).
  4. Participants will understand how IRC Section 864 and the 1.861-8 Treasury Regulations impact the benefits associated with IC-DISC and FDII.

  5. Participants will understand how the FDII deduction is reported on Form 8993.

Recording
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Export Incentives: Part 2b IC-DISC Breakout

January 30,  2025

Overview

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Learning Objectives

  1. Participants will understand the qualification requirements, including the setup of and IC-DISC.
  2. Participants will understand the fundamental of the DISC Pricing Rules.
  3. Participants will understand the additional tax benefits and requirements of marginal costing and the regular nd special no loss rules.
  4. Participants will understand how DISC taxable income is maximized using specialized software.
  5. Participants will understand how an IC-DISC can provide permanent tax savings through tax rate arbitrage in addition to tax deferral and related deferral strategies.
  6. Participants will understand the benefits associated with various IC-DISC ownership structures.

  7. Participants will understand the Reporting requirements of Form 1120-IC-DISC and related tax forms.

Recording
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VantagePoint Live Demo

February 6th, 2025

Learning Objectives

  1.  Participants will understand the interplay between U.S. international tax calculations and Pillar Two using VantagePoint Software.
  2. Participants will understand the 1.861-8 Allocation & Apportionment rules, including the consistency requirements between FDII and the Foreign Tax Credit using VantagePoint.
  3. Participants will understand how to fully automate the completion Form 1118 and other U.S. International Tax Forms using VantagePoint.
  4. Participants will understand the relationship between VantagePoint’s Foreign Tax Credit computations and the Allocation of GILTI and other Foreign Tax Credit Baskets for Pillar Two purposes.
Recording
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International Tax Update: Final 987 Regulations

February 25th, 2025

Learning Objectives

  1. Purposes of IRC 987 and Effective Date of the Final 987 Regulations
  2. Foreign Exchange Exposure Pool Accounting
  3. Annual Recognition Election
  4. Guidance on eligible pre-transition methods
  5. Current Rate Election
  6. Sourcing of 987 Gains and Losses
  7. Treatment of §987 within VantagePoint
Recording
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International Tax Update: PTEP Regulations

February 27th, 2025

Learning Objectives

  1. Overview, Effective Date and Open Items
  2. Understanding Section 961(c) Derived Tax Basis
  3. CFC and Shareholder Level Accounts and Share by Share Tracking
  4. Treatment by Consolidated Group Members
  5. Treatment of PTEP within VantagePoint
Recording
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International Tax Compliance Season Update 

June 3rd, 2025

Learning Objectives

  1. Summarize recent legislative developments affecting international tax compliance, with a focus on current U.S. proposals and their potential impact on multinational entities.
    Analyze a case study to identify key international tax reporting requirements and apply practical strategies for planning and compliance.
  2. dentify and explain the purpose and what is new in filing requirements for key foreign information reporting forms, including:
    Form 5471, including new Schedule H-1
    Form 4626 (Alternative Minimum Tax)
    Forms 8858 and 8865 (Foreign disregarded entities / branches and certain foreign partnerships)
    Describe the reporting obligations associated with U.S. international tax forms, including:
    Form 8975 (Country-by-Country Reporting)
    Forms 8990 and 8991 (Interest expense limitations and GILTI)
    Forms 8892 and 8893 (Extensions and elections related to international filings)
    Form 1118 (Foreign Tax Credit)
  3. Apply knowledge of international tax forms to ensure accurate and timely compliance with U.S. tax regulations for foreign operations and investments.
Recording
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Modeling OBBB International Tax Provisions 

July 10th, 2025

Highlights Include

• 863(b) – I’m Back!
• Net CFC TI (aka GILTI)
• FDII sans 367(d)
• Section 163(j) Updates
• The BEAT Goes On!

Comprehensive Tax Technical Updates
• Live VantagePoint™ Examples
• Scenario Comparison Reports

Learning Objectives

  1. The international tax provisions included in the recently enacted One Big Beautiful Bill Act.
  2. How to implement the new provisions using VantagePoint™ 3. The impact of the new provisions comparing pre-Act vs. OBBB Scenario Comparisons
  3. Treatment by Consolidated Group Members
  4. Treatment of PTEP within VantagePoint
Recording
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Manufactures Alliance Webinar: Modeling OBBB International Tax Provisions 

October 22nd, 2025

Overview

The recently enacted One Big Beautiful Bill introduces transformative international tax provisions that present both challenges and strategic opportunities for multinational corporations. Key updates include the return of Section 863(b), refinements to Net CFC Tested Income (GILTI), FDII without 367(d), enhancements to Section 163(j), and continued developments under the Base Erosion and Anti-Abuse Tax (BEAT) regime.

This session equips participants with the tools to implement the new provisions effectively and model their implications across global operations—empowering corporations to stay compliant while optimizing their tax positions.

Learning Objectives

  1. The international tax provisions included in the recently enacted One Big Beautiful Bill Act.
  2. How to implement the new provisions using VantagePoint™
  3. The impact of the new provisions comparing pre-Act vs. OBBB Scenario Comparisons.
Recording
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OB3 Modeling | A Case Study & VantagePoint New Release 

November 18th, 2025

Overview

Join FORTE for an in-depth webinar featuring a comprehensive OB3 Modeling Case Study. This webinar will provide a detailed analysis of OB3’s international tax provisions, illustrating their practical application through examples and highlighting the interplay of the US International Tax calculations under the new law. Expect actionable insights and expert guidance to help you navigate these significant changes with confidence. The VantagePoint™ new OB3 release will be announced.

Learning Objectives

  1.  The international tax provisions included in the recently enacted One Big Beautiful Bill Act.
  2. How to implement the new provisions using VantagePoint™ 3. The impact of the new provisions comparing pre-Act vs. OBBB Scenario Comparisons
  3. Treatment by Consolidated Group Members
  4. Treatment of PTEP within VantagePoint
Recording
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