Big changes are in store for companies operating overseas. The Biden Administration and Congress are both proposing major revisions to international taxation, as are foreign jurisdictions looking for a bigger share of corporate taxes. This self-study webinar will update tax and financial professionals on the latest rules and regulations, and what is currently being proposed, including:
- Legislative provisions
- Proposed and final regulations
- Potential tax reform outcomes
- Treasury "Green Book" recommendations for FY 2023
...and more.
To apprise accountants and tax professionals involved in international business of the expected changes to international taxation being proposed by the Biden Administration, Congress and foreign jurisdictions.
Presenters:
Jamal Aquil, Tax Associate, International, KPMG
Kevin Cunningham, Managing Director, KPMG
• Overview of Possible Tax Reform
Outcomes
- US and global (BEPS 2.0)
- Planning framework
- GILTI
- FDII
• Planning Themes
- Prepayment (goods, services,
royalties)
- FTC management
- Loss, inbound and VCM planning
• Treasury “Green Book” Details
for FY 2023
- International proposals
- Replacement of BEAT with
Undertaxed Profits Rule
- Expanded retroactive QEF
election
- Redefining Foreign Business
Entity for Reporting Purposes
• Section 958 Final Regulations
- PFIC and CFC proposals
- Domestic partnerships
• Proposed Regulations
- PFIC general background
- Proposed aggregate treatment for
QEF and MTM, and CFC Overlap
Rule
• Final FTC Regulations
- Tightening the scope of creditable
tax
- Attribution requirement (FKA
jurisdictional nexus)
- Affected taxes
- Rules for nonresidents vs.
residents
• Understand the proposed corporate tax rate changes by different political parties
• Identify specific budget proposals affecting the IRS and tax filing programs
• Learn about the IRS's enforcement strategies and planned resource increases
• Recognize key legal doctrines influencing IRS and Treasury regulatory practices
• Understand the objectives of Pillar I in the OECD’s international tax framework
• Identify the threshold criteria for businesses subject to the global minimum tax under Pillar II
• Explore the CJEU's stance on state aid and multinational tax practices within the EU
• Recognize different countries’ approaches to implementing Pillar II and federal corporate taxes
• Understand the compliance implications for multinational enterprises under Pillar II
• Identify how statute of limitations applies to Treasury regulations following recent court rulings