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.
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