Advanced Corporate Tax Planning & Emerging Issues Webinar
Overview
This session explores advanced tax planning developments and emerging issues affecting multinational businesses, investment funds, sovereign investors, and cross-border transactions. Participants will examine recent developments under Section 892, foreign entity of concern (FEOC) rules, controlled foreign corporation (CFC) provisions, and evolving IRS enforcement and regulatory trends. The session will also address practical considerations for tax planning, governance, and transaction structuring in an increasingly complex international tax environment.
Objective
To provide tax professionals with an update on advanced tax planning developments, regulatory changes, and emerging compliance considerations impacting foreign investment structures, tax credits, sovereign wealth funds, and multinational entities.
Emphasis
- Developments under Section 892 and practical considerations for sovereign wealth funds and investment structures
- Proposed and final regulations involving effective control, debt investments, and commercial activity rules
- Foreign entity of concern (FEOC), specified foreign entity (SFE), and foreign-influenced entity (FIE) rules and related tax credit implications
- Material assistance rules, supply chain considerations, and practical impacts on energy and credit transactions
- Changes to downward attribution rules, Section 951B, and controlled foreign corporation planning considerations
- Practical implications of evolving IRS staffing, funding, enforcement, and regulatory developments
- Proposed Section 899 developments, Pillar Two considerations, and cross-border tax policy uncertainty
Best practices for coordinating tax planning, fixed asset management, and financial reporting considerations
Speakers
Jen Sabin, Partner, Gibson Dunn
This course is included in the following subscriptions:
Need more than one course? Upgrade to a subscription and save.
View Subscriptions