Winter Webinar Series

Session 3

International Tax Compliance:
What’s New in the 2020 Form Set


Please join us Tuesday, 2/23 @ 10am CST for International Tax Compliance: What’s New in the 2020 Form Set, the final installment of our Understanding and Modeling Global Tax Winter Webinar Series.

Substantial changes have been made to the entire international forms set, which take into account the final as well proposed regulations.  

Some highlights include:

Form 1118 – Changes related to final foreign tax credit regulations.

Form 5471 – The IRS continues to add to Form 5471’s compliance requirements, including new filing categories and other substantive changes throughout its separate schedules. 

Form 8992 – The addition of new Schedule B for determining the GILTI inclusion amount of U.S. shareholder members of a consolidated group, to apply the rules of section 951A to each member in accordance with Regulations section 1.1502-51.

This webinar session will walk participants through numerical examples from the regulations, including the results to be reported on the forms.

Previous Sessions

Session 1

2020 International Tax "Legs & Regs" Highlights

– Impact of expanded carryback rules (TPC)
– Section 965 transition tax implications (Forte)
– New Section 163(j) options (TPC)

GILTI High-Tax Exclusion
– Winners and Losers (Forte)
– Applicability for Amended Returns (Forte)
– Making the Election (TPC)

Final Foreign Tax Credit Allocation and Apportionment Regulations
– Interest Expense and Asset Characterization (Forte)
– Research and Experimental Deductions (Forte)
– New Asset Base for Stewardship (TPC)

The instructors will provide specific citations to the new rules and demonstrate the calculation logic by guiding the participants through quantitative examples included in Treasury Regulations. The session will include an integrated Case Study using VantagePoint™ to reinforce the learning objectives and to demonstrate how the various provisions interrelate.

Impact on the GILTI High-tax Exclusion and other elections

VantagePoint Case Study

Session 2

Asset Characterization:
Impact on Interest Expense and Stewardship

Please join us for the second installment of our “Understanding and Modeling Global Tax” Winter Webinar Series, “Asset Characterization for §861-8 & Impact on Interest Expense, Stewardship + Income Taxes” this Thursday, 2/4 @ 10am CST.

The rules for allocating and apportioning deductions under Treasury Regulation § 1.861-8 are a major limiting factor in determining tax savings associated with the Section 250 GILTI/FDII deduction, the U.S. foreign tax credit and many other operative sections of the Internal Revenue Code. This webinar provides a detailed analysis of the substantially revised regulations covering the allocation and apportionment of the following deductions:

– Interest Expense
– Stewardship
– Research and Experimental
– Income Taxes

Special emphasis is focused on the Asset Characterization Rules prescribed in Treasury Regulation § 1.861-13 Special Rules for Characterization of Controlled Foreign Corporation Stock.

The session will walk participants through numerical examples included in the regulations as well as a VantagePoint™ Case Study demonstrating the interplay of multiple statutory groupings and the impact of the GILTI high-tax exclusion.