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 timely new webinar will update tax and financial professionals on the latest rules and regulations, and what is currently being proposed.
- Status of International Tax Projects
- Comparison of Biden vs. Other Proposals
- Global Intangible Low-Taxed Income Provisions
- High Tax Exception
- Foreign Derived Intangible Income
- Base-Erosion and Anti-Abuse Tax
- Section 163(j)
...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
- Taxation of US Shareholders of
CFC
- Status of Certain International Tax
Regulation Projects
- Biden vs. Wyden Proposal
- “Made in America” vs. “Over-
hauling International Taxation”
• Global Intangible Low-Taxed
Income (GILTI)
- Changes to TCJA
- Components of GILTI analysis
- Controlled foreign corporation
- US shareholder
- Pro Rata share
- GILTI inclusion and deduction
- Foreign tax credit
- GILTI calculation
- Net CFC tested income
- Net DTR
- GILTI inclusion
• GILTI High-Tax Exception (GILTI-
HTE)
- Process flow
• Section 250 Deduction—Foreign
Derived Intangible Income (FDII)
- Definitional framework
- Sales overview
- Services overview
- Section 250 deduction limitation
• Base-Erosion and Anti-Abuse Tax
(BEAT)
- Applicable taxpayer definition
- Percentage test
• Section 163(j)
- Overview and operative rule
- Proposed repeal of earning
stripping rules
