Past Events
Webinar: GloBE Information Return Webinar
November 19, 2024
10-11:30 am Central
Presented by:
Mark Gasbarra, CPA, Forte International Tax, LLC
David Merrick, JD, Forte International Tax, LLC
Eric Flueckiger, CPA, Forvis Mazars, LLP
John Karasek, JD, McDermott Will & Emery LLP
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.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One and a Half (1.5) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
November 19, 2024 | Online WebinarMore Information
2024 TEI 79th Annual Conference
Sponsor & Presenter
October 27-29, 2024 | San Antonio, TexasMore Information
Webinar: GloBE Information Return Webinar
September 12, 2024
10-11:30 am Central
Presented by:
Mark Gasbarra, CPA, Forte International Tax, LLC
David Merrick, JD, Forte International Tax, LLC
Wendy McDonald, CPA, Forte International Tax, LL
Kate Morton, CPA, Forvis Mazars, LLP
Eric Flueckiger, CPA, Forvis Mazars, LLP
John Karasek, JD, McDermott Will & Emery LLP
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
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One and a Half (1.5) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
September 12, 2024 | Online WebinarMore Information
IFA Virtual International Tax Conference
September 10
Traps for the Unwary in International Taxation
3:45-4:45 PM ET
Moderator: Pat Brown, PwC
Speakers:
Audrey Charling, GE
Mark Gasbarra, Forte
Eric Sloan, Gibson Dunn
Amanda Varma, Steptoe & Johnson
More Information
Webinar: International Tax Compliance Season Update
10:00-11:15am Central Time
Presented by:
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC
Wendy McDonald, CPA, Forte International Tax, LLC
Marilyn Jankowski, Forte International Tax, LLC
Alexis Bergman, CPA, JD, LLM, Baker Tilly LLP
Eric Flueckiger, CPA, Forvis Mazars, LLP
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
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One and a Half (1.5) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
July 16, 2024 | Online WebinarMore Information
Webinar: Pillar Two – Latest OECD Guidance Issued June 2024
2:00-3:15pm Central Time
Presented by:
Mark Gasbarra, CPA, Forte International Tax, LLC
David Merrick, JD, LLM, Forte International Tax, LLC
Wendy McDonald, CPA, Forte International Tax, LLC
Marilyn Jankowski, Forte International Tax, LLC
Alexis Bergman, CPA, JD, LLM, Baker Tilly LLP
Kate Morton, CPA, Forvis Mazars, LLP
Justin Metcalfe, CPA, Forvis Mazars, LLP
Learning Objectives
1. Understand DTL Recapture
2. Understand Allocation of Cross-border Taxes (Current & Deferred)
3. Understand the Allocation of Profits and Taxes, including Glow-through Entities
4. Understand the Treatment of Securitization Vehicles
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One and a Half (1.5) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
July 16, 2024 | Online WebinarMore Information
2024 TEI Tax Symposium
Sponsor
This Seminar is intended for in-house tax and accounting professionals needing to know the current and future state of tax reporting under the latest FASB pronouncements, as well as other significant financial reporting developments relevant to in-house tax professionals.
More Information
Deals, Compliance, and Planning for Multinationals in the Pillar Two Era
Request attendance to this invitation-only event featuring international tax professionals from McDermott Will & Emery and Forte International Tax, as well as local executive leaders in tax and finance.
This open-dialogue forum with high level tax professionals will take a deep dive into the legal, tax and reporting issues that have developed as a result of the implementation of Pillar Two.
Global effective tax rate planning and reporting is more complex than ever. Teradyne will share its success working with Forte’s VantagePoint software to integrate U.S. international tax calculations with Pillar Two requirements.
AGENDA
11:00 – 11:10 am | Registration & Introduction
11:10 am – 12:00 pm | Session 1 – The Q1 Reporting Experience
12:00 – 1:15 pm | Lunch & Session 2 – M&A and Executive Compensation
1:15 – 1:30 pm | Break
1:30 pm – 2:00 pm | Session 3 – Modeling
SPEAKERS
John Karasek, Counsel, McDermott Will & Emery, Moderator
Mark Gasbarra, National Managing Director, Forte International Tax, LLC
Drew Adams, Global Tax Director, Teradyne
Rob Marshall, Partner, McDermott Will & Emery
Wendy McDonald, Director, Forte International Tax, LLC
CLE/CPE Pending
June 6, 2024 | Boston, MAMore Information
2024 ACT Annual Tax Technology Conference
Sponsor & Presenter
May 20-22, 2024 | St. Petersburg, FloridaMore Information
TCPI – The Gathering Storm: 2025 and the Coming Tax and Fiscal Showdown
Sponsor & Presenter
May 16-17, 2024 | Washington, D.C.More Information
2024 Marcus Evans Tax Summit
The Tax Officers Summit is an invitation-only, premium Summit bringing leading Chief Tax Officers and innovative suppliers and solution providers together. The Summit’s content is aligned with key tax challenges and interests, relevant market developments, and practical and progressive ideas and strategies adopted by successful pioneers.
May 6-7, 2024 | Dallas, TexasMore Information
2024 TEI 6th Annual Tax Technology Seminar
Sponsor & Presenter
April 29-1, 2024 | Orlando, FloridaMore Information
Webinar: 2023 International Tax Compliance Update
Presented by:
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
April 18, 2024 | Online WebinarMore Information
Webinar: IC-DISC and FDII Optimization
Presented by:
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
April 11, 2024 | Online WebinarMore Information
Webinar: Foreign Parented Multinational Groups
Presented by:
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
April 4, 2024 | Online WebinarMore Information
Global Tax Optimization Boot Camp
Legal structures and entity classifications, transfer pricing, historical tax attributes, tax elections, and Treas. Reg. 1.861-8 methodology all matter and impact your results. They all must be modeled together to ensure data integrity, facilitating global tax optimization. For example, Pillar Two QDMTTs impact the US GILTI and FTC calculations, which then impact Pillar Two Final top-up taxes.This Global Tax Optimization (GTO) Bootcamp transforms the latest international tax requirements into practical ready-to-use implementation guidance, by combining detailed international tax technical analysis with an integrated Case Study.Early Bird Pricing will be available until March 1st. Take advantage of the group rate if you have more than 2 participants. Note, if you are a client or a 2023 Boot Camp participant, you will receive an invitation with a special discount code.
Pillar Two and U.S. Tax Interplay
Module 2
Subpart F, GILTI and High-Tax Income Elections
Module 3
Treas. Reg. 1.861-8, FDII and Foreign Tax Credit
Module 4
163(j), BEAT and CAMT
Program Level: Intermediate
# of CPE credits: Up to Six (6)
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
More Information
2024 Annual Conference International Fiscal Association (IFA)
Sponsor & Presenter
March 21-22, 2024 | New York, NYMore Information
2024 74rd TEI Midyear Conference
Sponsor & Presenter
Pillar Two Update & Implementation
Tuesday, 3/19/2024 | 11:15 AM – 12:15 PM EDT.
March 17-20, 2024 | Washington, D.C.More Information
Forvis Pillar Two Boot Camp: Part 2
Join Forvis and delve deeper into the technical nuances associated with Pillar Two’s global minimum tax. In this informative session, we’ll share how the Pillar Two global minimum tax works, the computation of the GloBE tax mechanics and the requisite adjustments needed, the various safe harbor tests released by the OECD, and the GloBE information return. In addition, these topics will be integrated into a practical case study for participants to follow.
Learning Objectives:
- Describe the general framework of the Pillar Two global minimum tax as enumerated by the OECD Inclusive Framework and subsequent administrative guidance.
- Recall the technical nuances surrounding GloBE adjustments.
- Discuss the technical aspects of the Pillar Two model rules.
More Information
Webinar: Repatriation Planning and APB23
Presented by:
Phil Laminack, CPA, FORVIS
Chris Clifton, CPA, FORVIS
Alexis Bergman, CPA, Baker Tilly
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
March 12, 2024 | Online WebinarMore Information
GloBE Meets GILTI: Ready, Set, Go!
Presented by:
John Karasek, JD, LLM, McDermott Will Emery
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC
This session covers IRS Notice 2023-80 including specific rules for the calculation interplay between Pillar Two and GILTI.
Specific learning objectives participants will derive from this session include:
1. Understanding how Pillar Two Qualified Domestic Top-up Taxes (QDMTT) impact the calculation of GILTI, including its impact on the GILTI High-Tax Exclusion
2. Understanding how QDMTTs impact the Subpart F High-tax Exception.
3. Understanding the definition of a Final Top-up Tax and the U.S. effect on members within and without the MNE Group
4. Understanding the interaction between the U.S. Dual Consolidated Loss Rules with the GloBE Rules
5. Understanding the Extension and Modification of Temporary Relief of the 2002 Foreign Tax Credit Regulations
A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
CLE credit is pending in CA, IL, NY (where McDermott is an approved CLE provider). A Uniform Certificate of Attendance will be made available to participants requesting CLE credit in all other Jurisdictions; which may be used to self-apply for CLE credit in their state of admission.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
January 11, 2024 | WebinarMore Information
Strafford Webinar: IC-DISC Strategies: Mastering the Complex Operational Challenges
A live 50-minute premium CPE webinar.
The tax savings available for exporters through an IC-DISC (interest charge-domestic international sales corporation) remain a significant incentive for businesses and their owners. Accounting professionals and corporate tax specialists must prepare for the burdensome tax and accounting challenges that come into play after implementing IC-DISCs.
Tax planning involving an IC-DISC requires more intensive review with the currently qualified business income deduction (QBID) for pass-through entities and the Section 250 deduction for FDII available to C corporations. These new demands add to higher-level compliance challenges for advisers to businesses.
Perspectives from advisers with years of experience in IC-DISC structures will help you deal with its most vexing tax challenges, including strategies for handling critical day-to-day operational aspects, calculating commissions, anticipating IRS audit risk areas, improving liquidity for the parent and shareholders, and identifying optimal approaches to complicated computational problems.
Our panel will prepare accounting professionals and tax advisers to fully leverage the tax benefits of IC-DISC formation. The panel will review and explain the key strategic steps for day-to-day aspects of running an IC-DISC, including calculating commissions, spotting IRS audit risks, and tackling the complex computations required. The panel will outline critical IC-DISC tax planning opportunities, including using the best DISC ownership structures to maximize DISC benefits.
We will guide you through issues including:
- Maximizing unique IC-DISC tax benefits such as the tax benefits from different shareholder structures
- Understanding tax liability for DISC structures and the QBID
- Managing day-to-day operational aspects of using an IC-DISC
- Improving liquidity for the parent and shareholders: steps to consider
- Overcoming computational challenges
After our presentations, we will engage in a live question and answer session with participants so we can answer your questions about these important issues directly.
November 30, 2023 | Webinar | 12:00pm-1:50pm CST
More Information
Pillar Two Boot Camp + Interactive Case Study
EARLY BIRD REGISTRATION IS OPEN THROUGH OCTOBER 20th
WEEK 1
Technical Sessions – 6 Modules M/W/F at 10 AM and 2 PM CDT – 9 CPE Hours
- OECD Guidance and Legislative Update
- Overview of OECD Guidance
- Jurisdictional Update
- Subject to Tax Rule (STTR)
- Top-Up Tax and Tax Accounting
- Operational Rules
- GloBE Income Adjustments
- Tax Adjustments
- Charging Provisions
- Qualified Domestic Top-up Tax (QDMTT)
- Income Inclusion Rule (IIR)
- Under Taxed Profit Rule (UTPR)
- Pillar Two Safe Harbours and Elections
- Safe Harbours
- Elections
- Penalty Relief
- Interplay with U.S. Tax Calculations
- S. Ultimate Parent Entity (UPE)
- Foreign UPE with U.S. Sandwich Structure
- UPTR Safe Harbour
- Corporate Alternative Minimum Tax (CAMT)
- GloBE Information Return
- Coordination Pillar Two Operational Rules
- Simplified Filing Requirements
- Surrogate Entity Jurisdiction
WEEK 2
Interactive Case Study – 5 hours of CPE
Participants work through a live fully-integrated Pillar Two Case Study in 5 sessions.
- Case Study Introduction and Financial Accounting Net Income or Loss
- Legal Structure
- Jurisdictional Tax Attributes
- Financial Accounting Net Income or Loss (FANIL)
- Chart-of-Accounts
- Trial Balances
- Tax Purposes, Adjustments and Country-by-Country Report
- Tax Purposes
- Adjustments
- Country-by-Country Report
- IRS Form 8975
- U.S. Tax Calculations and Pillar Two Reports
- Operational Rules
- GILTI, FDII and FTC
- Transitional Safe Harbour Report
- Pillar Two Report
- GloBE Information Return
- MNE Group Information
- Jurisdictional Safe Harbours and Exclusions
- GloBE Computations
- Wrap-Up and Final Polling and Q&A
- Jurisdictional Attributes
- FANIL and Adjustments
- S. Tax Calculations
- Pillar Two Reports
- GloBE Computations
Up to 14 CPE
This session covers OECD Guidance including the following two OECD documents published as of July 13, 2023:
• https://www.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-july-2023.pdf
• https://www.oecd.org/tax/beps/globe-information-return-pillar-two.pdf
Specific learning objectives participants will derive from this session include:
- Understanding the new Qualified Domestic Top-Up Tax (QDMTT) Safe Harbour
- Understanding the Transitional UTPR Safe Harbour for Jurisdictions subject to a Tax Rate of at least twenty percent
- Understanding the new guidance on tax credits including transferable credits
- Understanding the final changes to the GloBE Information Return (GIR)
A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Up to Fourteen (14)
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds are not available, except for duplicative registrations.
November 27-8, 2023 | WebinarMore Information
2023 Marcus Evans Tax Summit
The Tax Officers Summit is an invitation-only, premium Summit bringing leading Chief Tax Officers and innovative suppliers and solution providers together. The Summit’s content is aligned with key tax challenges and interests, relevant market developments, and practical and progressive ideas and strategies adopted by successful pioneers.
November 2-4, 2023 | JW Marriott Marquis | Miami, FLMore Information
2023 75th Anniversary Annual Conference
Sponsor & Presenter
More Information
Webinar: Preparing for the GloBE Information Return, Part III
New Pillar Two Updates – Final GloBE Information Return (GIR)
Tuesday, August 1st – 2:00 PM CDT
Up to 1 CPE
This session covers OECD Guidance including the following two OECD documents published as of July 13, 2023:
• https://www.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-july-2023.pdf
• https://www.oecd.org/tax/beps/globe-information-return-pillar-two.pdf
Specific learning objectives participants will derive from this session include:
- Understanding the new Qualified Domestic Top-Up Tax (QDMTT) Safe Harbour
- Understanding the Transitional UTPR Safe Harbour for Jurisdictions subject to a Tax Rate of at least twenty percent
- Understanding the new guidance on tax credits including transferable credits
- Understanding the final changes to the GloBE Information Return (GIR)
A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
August 1, 2023 | WebinarMore Information
Webinar: Preparing for the GloBE Information Return, Part II
Understanding Pillar Two Calculations and the GloBE Information Return: Part II
This session provides practical guidance on what you need to know in order to effectively prepare for the Pillar Two Global Minimum Tax (GMT). The session outlines the specific operational rules necessary to calculate GMT related Top-Up Taxes as well as the Transitional CbCR Safe-Harbour determinations. The components of the GloBE Information Return (GIR) are explained, including the specific data points necessary for tax administrations to evaluate the correctness of a Constituent Entity’s (CE) GloBE tax liability. A brief Case Study is presented to reinforce the calculation methodology including the interplay of Pillar Two with the GILTI tax calculations.
Learning Objectives
• Participants will learn the specific operational rules required to calculate potential Top-Up taxes under Pillar Two.
• Participants will understand the differences between the Pillar Two computations and those provided under the Transitional CbCR Safe Harbor provisions.
• Participants will understand how the Pillar Two computational determinations are presented in the GloBE Information Return (GIR).
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
June 12, 2023 | WebinarMore Information
2023 ACT Annual Tax Technology Conference
Sponsor & Presenter
“GloBE Meets GILTI – integrated modeling scenarios with and without the GILTI high-tax exclusion and CAMT”
May 24th 1:30pm -2:30pm ET
More Information
TCPI: Fostering Sound & Durable Tax Policy: The Vital Role of Business
Sponsor & Exhibitor
Join us at the 24th Annual Tax Policy & Practice Symposium as we examine the competing forces and the role of business in shaping the policy response to growing challenges. Over our two days together, leaders of the tax community will consider:
- The budget facts and options to bring spending and revenues into balance
- The role of income taxes and alternative tax bases in meeting governments’ revenue needs, and the political prospects for change
- The future of global tax policy whether implementation of the OECD’s two-pillar agreement fails or succeeds
- The implications of the increasing focus on ESG reporting and tax transparency
- Prospects for effectively channeling tax administration resources and promoting comprehensive cross-border dispute resolution for competing claims of jurisdiction to tax business profits
More Information
2023 TEI Tax Technology Seminar
Sponsor & Presenter
“Global Transparency and International Automation Outlook – Leveraging Automation to Keep Pace with a Changing World”
Tuesday, April 25
10:15 am – 11:15 am CDT
More Information
Webinar: Preparing for the GloBE Information Return
This session analyzes the underlying data points and calculations necessary to comply with Pillar Two.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
More Information
2023 73rd TEI Midyear Conference
Sponsor & Presenter
”Gathering, Wrangling and Utilizing Foreign Entity Data – How “Mature” Is Your Process?”
March 21st 11:00am -12:00pm ET
Moderator:
Ag Samoc – VP Tax Counsel, Danaher
Panelists:
Mark Gasbarra – Managing Director, Forte International Tax
David Flores -Director, Baker Tilly
Jamie Eagan – Director, insightsoftware
More Information
4th Annual | International Tax Boot Camp | Forte + FORVIS + Baker Tilly
UPCOMING ONLINE WORKSHOP
February 21st – March 9th
Business Days 10:00am-12:00pm CT & 2:00-4:00pm CT
-Up to 24 CPE-
-2 per Module-
4th Annual
International Tax Boot Camp
Join Forte International Tax, Forvis, and BakerTilly panelists for our Fourth Annual International Tax Boot Camp.
This workshop is designed to keep international tax professionals up to date with the latest provision and compliance requirements and the impact of proposed global tax initiatives, including Pillar Two.
The live virtual program will cover 2022 compliance requirements and late breaking developments for understanding and modeling outbound international tax calculations.
Up to 24 CPE credits will be provided for live registrants and all recordings will be available for replay.
Highlights
Latest International Tax Technical Content
- Practical, immediately useful knowledge, keeps you you up-to-date on the latest U.S. outbound international tax compliance requirements.
- Insightful tax saving strategies.
- Highly skilled instructors with decades of client-serving experience.
- Learning objectives are reinforced through integrated Case Study examples.
Click to learn more about the program and detailed learning objectives by Module.
Discounts are available for Early Bird Registrants, as well as for multiple persons by firm. We encourage your whole team to take advantage of the Group Rate. Are you a client or past Boot Camp participant? Email us to get an additional discount as a thank you.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Twenty Four (24)
More Information
GloBE Meets GILTI Update
GloBE Meets GILTI Update Webinar
Covering the Latest OECD Guidance Released February 1, 2023
This session covers important computational guidance approved by the OECD/G20 Inclusive Framework on BEPS on February 1, 2023. In particular, this guidance provides specific rules on how to allocate income taxes arising under Blended CFC Tax Regimes for purposes of calculating the effective tax rate of Constituent Entities for purposes of the Pillar Two Global Minimum Tax. The guidance approves GILTI as such a regime and allows the GILTI Tax to be allocated to each entity according to a specifically defined allocation key. This session explains the guidance and provides specific numerical examples of its practical application. A Case Study with and without the GILTI high-tax exclusion using Forte’s VantagePoint™ software will also be presented.
Discussion Topics
- Pillar Two Timeline/Update
- Overview of 2/1/2023 Guidance
- Specific rules with respect to Blended CFC Tax Regime including GILTI
- QDMTT Rules
Learning Objectives
- Participants will be gain an understanding of the Feb 1 update of the Pillar Two’s implementation timeline and status.
- Participants will understand how to allocate the GILTI tax cost for purpose of computing covered taxes for Pillar Two purposes.
- Participants will learn when a Qualified Domestic Top-Up Tax (QDMTT) will be included in covered taxes for Pillar Two purposes.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
February 15, 2023 | WebinarMore Information
What’s New in VantagePoint 2023
Please join us for a demonstration of the latest VantagePoint enhancements and those soon to be released, including the Corporate Alternative Minimum Tax (“CAMT”) and CAMT FTC.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: None
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
January 26, 2023 | WebinarMore Information
VantagePoint Demo – Integrated Modeling (no CPE)
VantagePoint Demo – Integrated Modeling incl GILTI, FDII, FTC and a look at Pillar Two (no CPE Offered)
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: None
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
December 9, 2022 | WebinarMore Information
Webinar: Repatriation and the APB23 Assertion
Overview of the topics discussed in this webinar:
A – PTEP/245A
B – FX Gains (Losses)
C – Withholding Taxes
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
November 16, 2022 | WebinarMore Information
2022 Marcus Evans Tax Summit
The Tax Officers Summit is an invitation-only, premium Summit bringing leading Chief Tax Officers and innovative suppliers and solution providers together. The Summit’s content is aligned with key tax challenges and interests, relevant market developments, and practical and progressive ideas and strategies adopted by successful pioneers.
November 6-8, 2022 | San DiegoMore Information
2022 77th TEI Annual Conference
Sponsor & Presenter
“GloBE Meets GILTI – Integrated Planning & Modeling Strategies”
Tuesday Oct 25th @ 11:00 AM-12:00 PM
More Information
Strafford Webinar: IC-DISC Strategies – Mastering the Complex Operational Challenges
A live 50-minute premium CPE webinar.
The tax savings available for exporters through an IC-DISC (interest charge-domestic international sales corporation) remain a significant incentive for businesses and their owners. Accounting professionals and corporate tax specialists must prepare for the burdensome tax and accounting challenges that come into play after implementing IC-DISCs.
Tax planning involving an IC-DISC requires more intensive review with the currently qualified business income deduction (QBID) for pass-through entities and the Section 250 deduction for FDII available to C corporations. These new demands add to higher-level compliance challenges for advisers to businesses.
Perspectives from advisers with years of experience in IC-DISC structures will help you deal with its most vexing tax challenges, including strategies for handling critical day-to-day operational aspects, calculating commissions, anticipating IRS audit risk areas, improving liquidity for the parent and shareholders, and identifying optimal approaches to complicated computational problems.
Our panel will prepare accounting professionals and tax advisers to fully leverage the tax benefits of IC-DISC formation. The panel will review and explain the key strategic steps for day-to-day aspects of running an IC-DISC, including calculating commissions, spotting IRS audit risks, and tackling the complex computations required. The panel will outline critical IC-DISC tax planning opportunities, including using the best DISC ownership structures to maximize DISC benefits.
We will guide you through issues including:
- Maximizing unique IC-DISC tax benefits such as the tax benefits from different shareholder structures
- Understanding tax liability for DISC structures and the QBID
- Managing day-to-day operational aspects of using an IC-DISC
- Improving liquidity for the parent and shareholders: steps to consider
- Overcoming computational challenges
After our presentations, we will engage in a live question and answer session with participants so we can answer your questions about these important issues directly.
October 20, 2022 | Webinar | 10:00-11:50am PDT
More Information
GloBE Meets GILTI – Pillar Two Update
Overview of the topics discussed in this webinar:
A – Latest OECD Guidance and Timeline
B – European Union Perspectives – Pillar II and DSTs
C – USA Landscape
D – Practical Modeling Solutions
Learning Objectives:
- The participants will understand the latest OECD Pillar II Guidance including the revised implementation timeline.
- The participants will understand the status of the EU’s acceptance of Pillar II as well as various DSTs.
- The participants will understand how various USA international tax rules interplay with Pillar II and gain practical insights on potential modeling scenarios.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Refunds: Due to this program being offered free of charge, there will be no refunds issued.
October 19, 2022 | WebinarMore Information
Webinar: Foreign Tax Credit Regulations (as corrected!) Plus: New Book Minimum Tax AMT FTC
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The ABC’s of Fully Integrated International Tax Modeling
Please join Forte International Tax, LLC for our upcoming webinar, “The ABC’s of Fully Integrated International Tax Modeling”
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.
August 3, 2022 | WebinarMore Information
2022 IFA Annual Conference
Sponsor
50th Annual Conference of the USA Branch of the International Fiscal Association
Thursday, June 2 and Friday, June 3, 2022
June 2-3, 2022 | Ritz-Carlton Washington D.C.
More Information
Webinar: International Tax Update New Schedules K-2/K-3
New Schedules K-2 and K-3
Forte BKD Webinar – Tuesday, 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.
Instructors:
Chris Clifton, BKD
Mark Gasbarra, Forte International Tax
Joshua Zellerman, BKD
May 31, 2022 | WebinarMore Information
2022 TCPI Symposium
Annual Tax Policy & Practice Symposium
“Seeking Stability in the Midst of Global Seismic Shifts”
May 19-20, 2022 | Washington, D.C.More Information
3rd Annual | International Tax Boot Camp | Forte + BKD + TPC
UPCOMING ONLINE WORKSHOP
April 18-27, 2022
Business Days 11:00-1:00pm CT
-Up to 16 CPE-
-2 per Module-
3rd Annual
International Tax Boot Camp
VIEW PROGRAM & REGISTER
Join Forte International Tax, BKD, and TruePartners Consulting for our third annual International Tax Boot Camp | LIVE Online Workshop | April 18-27. The program will cover 2021 compliance requirements and late breaking developments. Up to 16 CPE credits will be provided for live registrants.
In addition to the highlights below, this in-depth presentation will include an update on Pillars One and Two (“GloBE”) including the interplay with the U.S. international tax regime. Detailed instructions on completing the 2021 international tax forms, including Form 5471 and 1118, will be covered as well as valuable insights on available tax elections, repatriation planning and ASC740 aspects.
Highlights
- Latest International Tax Technical Content
- Foreign E&P, Subpart F and GILTI
- Foreign Derived Intangible Income
- GILTI/FDII Section 250 Deduction
- Reg. Section 861-8, et al
- Foreign Tax Credit
- Modeling Global & US International Tax Proposals
- OECD Pillars One & Two
- State treatment Foreign Income
- ASC740/APB23
Learning Objectives
Participants will gain understanding of the following:
- Understanding the primary international tax reporting and underlying computational requirements of U.S. Corporations and other U.S. Shareholders with operations outside of the U.S.
- Understanding the most up to date international reporting requirements including Forms 8858, 8865, 8975, 5471 and 1118 as clients are navigating the 2021 tax compliance season.
- Understanding how U.S. international tax attributes are reported for ASC740 purposes.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Sixteen (16)
April 18-27, 2022 | Online Workshop
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2022 TEI’s 72nd Hybrid Midyear Conference
Sponsor & Presenter
Wednesday, March 23, 9:45-10:45 am
International Tax Modeling Update – Challenges and Opportunities
This session provides international tax modeling strategies to deal with increasingly dynamic and complex international tax environment. The panel discusses the latest OECD guidance relatedto Pillars One and Two and how conforming U.S. legislation, including aspects of Build Back Better, may or may not follow. An integrated software model using Forte’s VantagePoint software will be presented.
March 20-23, 2022 | Washington, D.C.More Information
International Tax Update: Final Foreign Tax Credit Regulations | Part 2
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
Program Field of Study:
Taxes Program Level: Intermediate
# of CPE credits: One (1)
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International Tax Update: FTC Regulations
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.
# of CPE credits: One (1)
February 7, 2022 | WebinarVantagePoint 10.0 Release
January 23, 2021 Release Notes Summary:
- APB23 Calculations
- Chain-by-Chain
- Rollup of Distributable Reserves
- Enhanced Distribution Logic
- Pro-rata share Blocks
- Subs/Own Parameter
- 163(j) CFC Group Election
- Final consolidation regulations
- Automatic for 2021 tax years
More detailed Version 10.0 Release Notes will be posted on the VantagePoint Resources Page.
Please contact your support team for further assistance.
January 23-30, 2022 |International Tax Update: Repatriation Modeling Webinar
Repatriation Modeling Webinar
Special 3-Hour Session
December 8, 2021
1:00 PM – 4:00 PM Central Time
The Tax Cuts and Jobs Act (“TCJA”) dramatically changed the U.S. income tax treatment of the repatriation of foreign earnings. Now, even though IRC Section 245A allows a 100% Dividends Received Deduction (“DRD”) on dividend remittances to corporate shareholders, much of those earnings will have already been subject to U.S. income tax under either the GILTI or Subpart F regime. As a result, many distributions will be out of previously taxed earnings and profits (“PTEP”).
In this session, special attention is paid to the long-established distribution ordering rules prescribed by IRC Section 959 and the Treasury Regulations thereunder. We also explain how those rules have been modified as a result of the Section 965 transition tax and the creation of multiple PTEP accounts and the priority given to Section 965 PTEP accounts within each of the Section 959 layers. PTEP distributions can result in significant foreign exchange gains and losses, and foreign tax credits may be allowed on any additional foreign taxes incurred on PTEP distributions, subject to complex requirements.
During this webinar we will walk participants through the impact of these rules, both by an analysis of the regulation examples, as well as performing how-to-model calculations using Forte’s VantagePoint software.
Learning Objectives:
Understand the distribution ordering rules outlined in IRC Section 959 and the special adjustments relating to Section 965 PTEP Accounts.
Understand how additional income taxes paid on previously taxed income are available for foreign tax credit purposes.
Understand the importance of repatriation modeling for income tax provision purposes.
Discuss how each of the tax requirements is reported on the related international tax forms.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Three (3)
More Information
2021 Marcus Evans Tax Summit
The Tax Officers Summit is an invitation-only, premium Summit bringing leading Chief Tax Officers and innovative suppliers and solution providers together. The Summit’s content is aligned with key tax challenges and interests, relevant market developments, and practical and progressive ideas and strategies adopted by successful pioneers.
November 7-9, 2021 | Orlando, FloridaMore Information
TEI 76th Annual Conference
Sponsor & Presenter
“Modeling Potential Impacts of Legislation and Planning Alternatives”
Tuesday, 10/26/21 2-3 PM EDT Session
Presenters:
Katrina Welch, Gordon Food Service, Moderator
Mark Gasbarra, National Managing Director, Forte International Tax
Alexis Bergman, International Tax Director, True Partners Consulting
George Salis, Principal Economist & Tax Policy Advisor, Vertex
Session Description:
As tax regimes have gotten increasingly complex and integrated so too has the critically important task of modeling their financial impacts. Hard lessons learned in late-night modeling sessions concerning TCJA planning and implementation spurred significant interest among TEI members seeking a better way to design and build tax models. This session brings together a diverse group of leading tax and technology professionals to share experiences, offer insights and inform participants of advances in building financial models. Our panelists will engage in an interactive dialogue, covering topics, such as situations in which tax models are useful and how decision-makers use them; different approaches for creating tax models and when to use them; how and when tax modeling should be automated; decision-points to consider when deciding upon a modeling approach; and resources for tax modeling.
Learning Objectives:
At the conclusion of this course, participants should:
- Understand how tax models can be useful for decision-making and when to apply them;
- Be aware of different approaches for creating tax models and when to use the different approaches;
- Understand how and when tax modeling should be automated;
- Identify decision-points to consider when deciding upon a modeling approach;
- Be aware of different resources for tax modeling.
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Forte Webinar: The GILTI High-Tax Exclusion and Treas. Reg. 861-8
Join Forte September 2nd @10am for a timely webinar on “The GILTI High-Tax Exclusion & Treas. Reg. 861-8” and earn CPE credit.
Summary:
The impact of Treas. Reg. 861-8 regulations at both the CFC and US shareholder level is a major driver on the U.S. tax cost of the GILTI regime.
Significant potential tax savings may be available by electing the GILTI high-tax exclusion but those savings can only be realized through complex modeling exercises including the impact of the CFC stock characterization rules prescribed in Treas. Reg. Section 1.861-13.
In this session, special attention is paid to the modified gross income method of apportioning interest expense at the CFC level, which becomes the basis for characterizing the CFC’s stock basis and PTEP/E&P Bump. This CFC stock characterization in-turn is a key component of the US shareholder’s asset base used for apportioning the US shareholder’s interest expense and stewardship expenses to various categories of foreign source income, including GILTI and income qualifying for the Section 245A 100% dividends received deduction.
During this webinar we will walk participants the impact of these rules both by an analysis of the regulation examples as well as performing how-to model calculations using Forte’s VantagePoint software.
Learning Objectives:
– Explain how Treas. Reg. 861-8 regulations impacts the GILTI High Tax Exclusion.
– Identify how to determine the quantitative aspects of the related tax technical requirements.
– Discuss how each of the tax requirements is reported on the related international tax forms.
Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: 1
September 2, 2021 | WebinarMore Information
International Tax Boot Camp 2.0
INTERNATIONAL TAX BOOT CAMP 2.0
2020 TAX COMPLIANCE UPDATE & MODELING SCENARIOS
For more in-depth training, we invite you to attend our International Tax Boot Camp 2.0 Training.
CPE CREDITS: Up to 8 CPE credits in the Taxes field of study may be awarded upon verification of participant attendance.
Highlights Include:
Latest International Tax Technical Content
- Foreign E&P, Subpart F and GILTI
- Foreign Derived Intangible Income
- GILTI/FDII Section 250 Deduction
- Reg. Section 861-8, et al
- Foreign Tax Credit
Modeling Global & US International Tax Proposals
- OECD Pillars One & Two
- Biden Administration Proposals
- Senator Wyden Proposals
More Information
Strafford Webinar: Tax Considerations of Repatriation
“Tax Considerations of Repatriation: Previously Taxed E&P, Non-PTEP, Return of Capital, Multi-Tiered Distributions”
This webinar will cover repatriation issues for multinational taxpayers. Our panel of foreign tax experts will examine distributions of E&P from PTEP, non-PTEP, and the return of basis and explain the tax considerations and benefits available for each distribution type.
Tuesday, June 8, 2021
1:00pm-2:50pm EST (10:00am-11:50am PST)
Panelists:
Mark C. Gasbarra, CPA
National Managing Director
Forte International Tax
Patrick J. McCormick, J.D., LL.M
Partner
Culhane Meadows Haughian & Walsh
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Chicago Tax Club: International Tax Compliance Update and Modeling Scenarios
Hosted by Forte International Tax, LLC
Co-hosted by True Partners Consulting, LLC
Mark Gasbarra, National Managing Director, Forte
Alexis Bergman, Director, TPC
This session focuses on the latest international tax compliance requirements and time-sensitive modeling scenarios.
More Information
ACT 2021 Virtual Annual Conference
Sponsor & Presenter
International Tax Modeling – Seize the Data and Seize the Day
Wednesday, May 26, 2021 @ 10:45 ET
This session focuses on some of the most critical modeling imperatives in the dynamic world of intentional tax, including global tax policy aimed at the digital economy. Moving closer to home, the discussion drills into U.S. international modeling including foreign branch vs. controlled foreign corporation comparisons, the whys and wherefores of the GILTI high-tax exclusion, and repatriation planning. A fully integrated Case Study covering GILTI, FDII and Foreign Tax Credit will be presented.
+ Visit our Vendor Lounge for a chance to win $100 donation for your favorite non-profit and more!
Wednesday, May 26, 2021 @ 10:45 ET
May 24-26, 2021 | Virtual ConferenceMore Information
Marcus Evans Tax Summit
The Tax Officers Online Summit is an invitation-only, premium Summit bringing leading Chief Tax Officers and innovative suppliers and solution providers together. The Summit’s content is aligned with key tax challenges and interests, relevant market developments, and practical and progressive ideas and strategies adopted by successful pioneers
May 5-7, 2021 | OnlineMore Information
Marcus Evans Webinar
Presenting:
International Tax Modeling: Foreign Branch vs. CFC Subpart F vs. GILTI
Speakers:
- Nancy Loube, VP of Tax, Brunswick Corporation
- Dana Harper, Director, International Tax, Deckers Brands
- Mark Gasbarra, National Managing Partner, Forte International Tax LLC
More Information
TEI 2021 Midyear Conference
Sponsor
Presenting
Regulatory Update – FTC/GILTI/FDII – Technical Issues and Modeling Considerations
Moderator:
Susan L. Curley, Ingram Industries, Vice Chair, TEI’s U.S. International Tax Committee
Speakers:
- Michael J. Caballero, Covington & Burling LLP
- Mark Gasbarra, Forte International Tax LLC
- Adam S. Halpern, Fenwick & West LLP
The TCJA and subsequent administrative guidance continues to result in unexpected and sometimes surprising outcomes for multinational taxpayers’ tax planning and modeling, reaching in some cases counterintuitive results and upsetting old “rules of thumb.” This session will provide an update on the latest in regulatory and other guidance with respect to the worldwide allocation of interest expense, foreign tax credit, sourcing rules, new capitalization rules, and show the complex modeling necessary to produce predictable results under the TCJA’s GILTI and FDII regimes.
Learning Objectives: After this session, participants will be able to: (1) understand recent U.S. international tax regulatory changes; (2) assess the impact of such changes on their employers’ business operations; and (3) describe the factors that should be accounted for when modeling tax outcomes under the TCJA.
March 22-25, 2021 | Washington, D.C.More Information
2nd Annual International Tax Boot Camp
For more in-depth training, we invite you to attend our 2nd Annual International Tax Boot Camp Training.
Topics Covered:
U.S. International Tax Compliance Calculations
Transfer Pricing and Country-by-Country Reporting
ASE 740 Tax Provision Analysis
Tax Attributes and Repatriation Planning
Update on 2020 International Tax Forms
More Information
International Tax Compliance – What’s New in the 2020 Form Set
*Complimentary Winter Webinar Series*
Forms 1118, 5471, 8992, and more.
February 23, 2021 | Webinar 10:00 AM CSTMore Information
Virtual 2021 TCPI Symposium
Annual Tax Policy & Practice Symposium
“Tax in a Time of Global Disruption: The Future Accelerated & Transformed”
February 10-12, 2021 |More Information
Asset Characterization – Impact on Interest Expense and Stewardship
*Complimentary Winter Webinar Series*
Modified Gross Income Method
Treas. Reg. 1.861-13
More Information
2020 Highlights – International Tax Legislation and Regulations
*Complimentary Winter Webinar Series*
CARES Act
GILTI High-tax Exclusion
Final FTC Regulations
More Information
Repatriation Analysis | PTEP & Tax Basis
*Complimentary Fall Webinar Series*
Participants will understand the impact of foreign earnings and profits, including previously tax earnings and profits, and tax basis on the following areas:
· Repatriation analysis
· ASC 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
The latest tax technical guidance, numerical Treas. Reg. Examples, and an integrated VantagePoint™ Case Study will be provided.
December 3, 2020 | Webinar 10:00 AM CSTMore Information
Understanding & Modeling the CARES Act
*Complimentary Fall Webinar Series*
Practical guidance in understanding and Modeling the CARES Act focusing on the international tax aspects, including:
- NOL Carryback and related provisions
- Interplay between NOL, Section 965, GILTI, FDDI, 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
More Information
Stafford Webinar: IC-DISC Strategies
“IC-DISC Strategies: Mastering Complex Challenges”
A live 110-minute CPE webinar with interactive Q&A
Tuesday, November 10, 2020
1:00pm-2:50pm EST (10:00am-11:50am PST)
Panelists:
Mark C. Gasbarra, CPA
National Managing Director
Forte International Tax
Randall Janiczek, CPA
Partner
Plante & Moran
Robert J. (Rob) Misey, Jr.
Shareholder
Reinhart Boerner Van Deuren
More Information
Understanding & Modeling the GILTI High-Tax Election
*Complimentary Fall Webinar Series*
Panelists:
Mark C. Gasbarra, CPA
National Managing Director
Forte International Tax
Lester Fuwa
Managing Director
Forte International Tax
Scott Bozzi
International Tax Consultant
Forte International Tax
More Information
2020 TEI 75th Annual Virtual Conference
Sponsor & Presenter:
Presentation at 5:00 pm-6:30 pm Tuesday October 27th
“International Tax Modeling Primer: BEAT, GILTI, 163(j), FDII, FTC”
8th.
October 26-28, 2020 | Virtual
More Information
2020 ACT Virtual Conference
Sponsor & Presenter:
“International Tax Transformation & CAREs Act” @ 9:10 am CDT Tuesday May 19th
Vendor Expo @ 6:15-7:00 pm CDT Tuesday May 19th
May 18-20, 2020 | Virtual
More Information
NEW: International Tax Bootcamp Registration
Registration opens March 1st.
April 30-1, 2020 | Webinar CourseMore Information
2020 TEI 70th Midyear Conference – CANCELLED
Sponsor & Presenter:
Class at 11:30-12:30 am Tuesday March 24th
“Strategic Global Tax Modeling – Tools & Techniques”
March 22-25, 2020 | Washington, D.C.More Information
48th Annual Conference of the USA Branch of the International Fiscal Association
Attendee
February 27-28, 2020 | Boston, MAMore Information
2020 TEI Tax & Tax Technology Seminar
Speaker
February 24-26, 2020 | Scottsdale Plaza Hotel - Scottsdale, AZMore Information
TCPI Annual Symposium
Hindsight is 2020: What the TCJA and Global Developments Tell Us About the Future of Tax
Sponsor, Booth 8
February 13-14, 2020 | Washington, DCMore Information
2020 Tax Legislative and Regulatory Update Conference and Reception with DC Bar
Sponsor
January 23, 2020 | Washington, D.C.More Information
32nd Annual Institute on Current Issues in International Taxation
Attendee
December 19-20, 2019 | Washington, D.C.More Information
TEI Annual Conference: Tax Department Transformation: From Technology to the TCJA
October 28-30, 2019 | New Orleans, LAMore Information
IC-DISC & FDII Strafford Webinar: U.S. Export Incentives Post-Tax Reform, Pricing Commissions, and Structuring Corporate Entities
Maximizing Tax Savings, Pass-Through Entities vs. C Corporations, Distributor Companies, and Alternative Ownership Structures
A live 90-minute premium CLE/CPE webinar with interactive Q&A
More Information
2019 Association for Computers and Taxation (ACT) Annual Conference: Corporate Tax Automation
Presenter & Sponsor
International Tax Automation in a Post-Tax Reform World
More Information
CorpTax University: ASC 740 Accounting For Income Taxes
Presenter
U.S. Foreign Income Tax and Manufacturing Credits
More Information
Tax Executive Institute (TEI) Minnesota Chapter’s 36th Annual President’s Seminar
Sponsor
April 23-24, 2019 | Minneapolis, MNMore Information
Tax Executives Institute (TEI)’s 69th Midyear Conference
GILTI/FDII/FTC/BEAT – Global Tax Integration
Presenter
More Information
Tax Executives Institute (TEI) Tax and Tax Technology Seminar
GILTI/FDII/FTC/BEAT – Global Tax Integration
Presenter
Client Panelist: Texas Instruments – Vera Cretcher
Firm/Vendor Speaker: Forte International – Mark Gasbarra & Thomson Reuters (Orbitax team)
Moderator: Sandhya Edupuganty
More Information
47th Annual Conference of the USA Branch of the International Fiscal Association
Exhibitor & Attendee
February 21-22, 2019 | Washington, DCMore Information
Tax Council Policy Institute (TCPI): The evolving boundaries of tax
Sponsor
February 14-15, 2019 | Washington, DCMore Information
Tax Executives Institute, Inc. (TEI) New York Chapter 55th Annual Tax Symposium
Sponsor
December 6, 2018 | New York, NYMore Information
CorpTax University Training: ASC 740 Accounting for Income Taxes Training
Presentation: U.S. Foreign Income Tax Credit
December 6-7, 2018 | Plano, TXAssociation for Computers and Taxation (ACT) Webinar: GILTI, FDII, FTC and the Impact of 861-8
This webinar uses an integrated case study to illustrate the impact of 861-8 on Sec. 965, GILTI, FDII, and FTC.
Description
The allocation and apportionment of deductions under Treas. Reg. Section 1.861-8 is a critical factor in calculating the following statutory provisions:
- Subpart F Income;
- Global Intangible Low-taxed Income (“GILTI”);
- DISC Taxable Income;
- Domestic Production Activities Deduction;
- Foreign Derived Intangible Income (“FDII”); and
- Foreign Tax Credit Limitations.
This session focuses on the application of the 1.861-8 regulations using an integrated Case Study to demonstrate the impact on Subpart F, GILTI, FDII, and the separate FTC limitations. The Case emphasizes the need to perform “what-if” modeling using alternative methods, especially considering the uncertainty surrounding the impact of 1.861-8 on the GILTI deduction.
Speaker Bios
Mark Gasbarra, National Managing Director, Forte International Tax
With over 30 years of industry experience, Mark has helped many of the country’s most successful enterprises implement all aspects of international taxation. A hallmark of Mark’s career has been leveraging technology to improve tax department performance. Prior to founding Forte International Tax, Mark held leadership positions at PwC, Ernst & Young, and CliftonLarsonAllen. Mark leads the firm on its mission of achieving global tax minimization through process efficiency.
Sandhya Edupuganty, Corporate Tax, Texas Instruments Incorporated
Sandhya has over 30 years of tax experience in multinational corporations as well at Big 4 accounting firms in direct and indirect tax, federal, state and international tax and tax compliance and tax accounting roles. She has a bachelors in commerce from St Francis College, India and a Masters in Accounting (specialization in tax) from University of Alabama, Birmingham. Building on tax technical skills, she has focused the second half of her career on streamlining processes to reduce risk through tax technology. She is an active member of Tax Executives Institute and ACT.
More Information
Strafford Webinar: IC-DISC and FDII: U.S. Export Incentives Post-Tax Reform, Pricing Commissions and Structuring Corporate Entities
Presenter
July 31, 2018 | 1:00pm-2:30pm EDT/10:00am-11:30am PDT WebinarMore Information
2018 Association for Computers and Taxation (ACT) Annual Conference
Sponsor
May 21-23, 2018 | San Diego, CAMore Information
Illinois Chamber of Commerce’s 4th Annual Export Conference: Global is Local: Developing a 21st Century Trade Policy That Works for Illinois
Presenter and Panel Sponsor
Presentation: Tax Reform, Leveling the Playing Field and Export Tax Incentives
More Information
Tax Council Policy Institute’s (TCPI) 19th Annual Tax Policy & Practice Symposium
“Disruption and opportunity in the era of global tax transformation”
Exhibitor (Table 11
More Information
BKR International: International Tax Committee Telemeeting
Presenter
U.S. International Tax Reform: Leveling The Playing Field
More Information
BKR International: Manufacturing Committee Telemeeting
Presenter
Implementing Tax Reform Proposals for Closely Held Manufacturers
More Information
BKR International: International Tax (Americas) Committee Telemeeting
Update on IC-DISC
October 6-6, 2017 | WebinarMore Information
Strafford Webinar: IC-DISC Strategies
Presenter
October 5, 2017 | 1:00pm-2:50pm EDT/10:00am-11:50am PDT WebinarMore Information
ACT Webinar
Leveraging Technology to Deliver Tax Savings: How to Optimize the Domestic Production Activities Deduction & FTC Utilization
August 8, 2017 | Webinar 1:00 PM CDTMore Information