International Taxation: What's New Webinar (1 Hour)

Overview: 

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, icnluding:

  • Legislative provisions
  • Proposed and final regulations
  • Potential tax reform outcomes
  • Treasury "Green Book" recommendations for FY 2023

            ...and more.

Objective: 

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

Emphasis: 

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

Bottom
Prerequisite: 

Basic knowledge of federal taxation and some level of international taxation.

Preparation: 

No advance preparation required.

Level of Knowledge: 

Basic.

CPE Credit: 
1.00
NASBA Field of Study: 
Taxes