International Taxation Update - Post OBBBA Self Study Webinar
Overview
Cross-border tax planning has never been more complex, with global regulations evolving and enforcement priorities shifting. This self-study webinar helps CPAs and tax professionals understand the broader forces shaping the international tax landscape and what they mean for corporate strategy and compliance. Through expert insights and practical examples, you’ll gain a clearer perspective on how to anticipate challenges, make informed decisions, and navigate today’s dynamic tax environment.
SPEAKERS:
Matt Donnelly, Partner, Gibson, Dunn & Crutcher, Washington DC
Benjamin Fryer, Partner, Gibson, Dunn & Crutcher, London
Anne Devereaux, Of Counsel, Gibson, Dunn & Crutcher, Los Angeles
Objective
To update CPAs and other financial professionals on the latest developments in financial reporting from the FASB. You’ll learn how to apply all of the most recent pronouncements effectively and efficiently, and get an overview of the latest SASs and other current auditing issues.
DETAILED LEARNING OBJECTIVES
• Understand the major structural changes to the IRS introduced in 2025, including the elimination of key divisions and the impact on tax administration
• Recognize the extent of IRS leadership turnover in 2025 and its implications for regulatory consistency and enforcement
• Explain the effect of Executive Order 14192 on the federal regulatory process and its specific application to the IRS
• Identify how the One Big Beautiful Bill Act (OBBBA) modified the GILTI regime, including the transition to Net CFC Tested Income (NCTI)
• Understand which international tax provisions were made permanent under OBBBA, specifically the CFC look-through rule
• Recall the new permanent BEAT rate established by OBBBA for tax years beginning after December 31, 2025
• Describe the purpose and scope of the OECD/G20 Pillar II initiative, including the 15% global minimum tax framework for large multinational enterprises
• Explain the substance of the “side-by-side” solution reached by the G7 and U.S. Treasury in 2025 and its recognition of U.S. NCTI/GILTI as compatible with Pillar II
Emphasis
- Sweeping changes to the IRS and US international tax regime following the inauguration of President Trump
- Effects of significant IRS downsizing, including impacts on regulatory guidance
- International tax provisions following the enactment of OBBBA
- Refresher on Pillar II, latest developments including the shift to a “side-by-side” solution, and predictions for future implementation
Speakers
Matt Donnelly, Partner, Gibson, Dunn & Crutcher, Washington DC
Benjamin Fryer, Partner, Gibson, Dunn & Crutcher, London
Anne Devereaux, Of Counsel, Gibson, Dunn & Crutcher, Los Angeles
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