Bootcamp

Registration is closed. 
Please email alavigne@forteintax.com if you would like to receive information about the recorded online Boot Camp or future learning events.

PREPARING INTERNATIONAL TAX PROFESSIONALS
FOR THE COMPLIANCE SEASON

April 30 & May 1, 2020

This live online workshop covers all international tax aspects of the TCJA including GILTI, FDII, FTC, 163(j) and BEAT. The latest tax technical content is explained and then implemented through fully integrated case studies that the participants will work though using VantagePoint.

Alternative modeling scenarios will cover aspects of both proposed and final tax regulations, including the apportionment of Stewardship and Research and Experimental deductions, and the use of various tax elections.

Case Study tax results will also be mapped to the 2019 International Tax Forms, giving participants an advanced guide to the latest international tax reporting requirements.

Online Modules will be delivered over a 2-day period for 8 hours of CPE.

LEARNING MODULES

THREE HANDS ON LEARNING MODULES ILLUSTRATE THE POWER OF INTEGRATED INTERNATIONAL TAX PLANNING, PROVISION, AND COMPLIANCE

All Modules include:
Technical Overview
Hands-on Case Study
International Tax Forms

MODULE 1

Organization/Supply Chain

MODULE 2

Historic Tax Attributes

MODULE 3

Foreign E&P, Subpart F & GILTI

MODULE 4

Global Low-Taxed Intangible Income (“GILTI”)

MODULE 5

Section 250 GILTI/FDII Deduction

MODULE 6

Foreign Tax Credit

MODULE 7

Global Tax Modeling and Planning

MODULE 8

Capstone

LEARNING OBJECIVES

This workshop is designed to help prepare international tax professionals for the tax compliance season.  As a result of active participation, program recipients be able to meet the following learning objectives:

Fundamental understanding of the internal revenue code sections and administrative guidance related to the outbound aspects U.S. international tax system.

Understand how to determine the quantitative aspects of the related tax technical requirements.

Understand how each of the tax requirements is reported on the related international tax forms including, 5471, 8858, 8975, 8992, 8993 and 1118.

Highlights include...

Latest International Tax Technical Content

  • Foreign E&P, Subpart F and GILTI
  • Foreign Derived Intangible Income
  • GILTI/FDII Section 250 Deduction
  • Reg. Section 861-8, et al
  • Foreign Tax Credit

Fully Integrated – Hands-On Calculation Experience

All calculations are mapped to automatically populate the 2019 International Tax Forms via VantagePoint™ Data Binding

  • 8875 – Country-by-Country Report
  • 8858 – Foreign Branch and Disregarded Entities
  • 5471 – Controlled Foreign Corporations
  • 8990 – Section 163(j) Limitation on Business Interest Expense
  • 8991 – Base Erosion Minimum Tax (“BEAT”)
  • 8992 – Global Intangible Income (“GILTI”)
  • 8993 – Section 250 GILTI/FDII Deduction
  • 1118 – Foreign Tax Credit

Registration

Registration is closed. 
Please email alavigne@forteintax.com if you would like to receive information about the recorded online Boot Camp or future learning events.

Delivery Methods

This is an online workshop with live interaction with highly skilled and experienced program instructors. 

The program is delivered through 8 distinct but interrelated topical session.  Each of the 8 sessions includes an overview of the latest international tax technical content, numerical examples explaining the underlying computational requirements, and how to report the computational results on the related tax forms. 

A comprehensive case study is used to integrate the individual learning objectives.

Refunds are accepted for duplicative registration only.

Prerequisites

International Tax Experience

Program Level

Intermediate

Advance Preparation

None

Preliminary Program

Day One – Morning Sessions 10:00 AM – 12:00 PM CST

1A – Organization/Supply Chain

  • Case Study Overview
  • Legal Entities
  • Supply Chain
  • Financial Statement Summary
  • Related Party Transactions
  • Form 8975 Country-by-Country Report

Break – 10:50 – 11:00 AM

1B – Historic Tax Attributes

  • Earnings and Profits and Tax Basis
  • Previously Taxed Earnings and Profits (“PTEP”)
  • Ordering Rules
  • Forms 5471, 8858 and 8865

Day One – Afternoon Sessions 2:00 PM – 4:00 PM CST

1C – Foreign E&P, Subpart F and GILTI

  • Earnings and Profits Adjustments (“E&P”)
  • Section 163(j) and U.S. Taxable Income
  • Subpart F, Exceptions and Elections
  • Subpart F vs. GILTI
  • Deemed Paid FTC
  • Forms 8858, 5471, 8990, 1118 and 1120

Break – 2:50 – 3:00 PM

1D – Global Low-Taxed Intangible Income (“GILTI”)

  • US Shareholders and Consolidated Filing Group
  • Tested Income and Tested Loss
  • Reg. Section 1.861-8, et al
  • Section 960 Allocation of Income Taxes
  • Qualified Business Asset Investment (“QBAI”)
  • Net Deemed Tangible Income Return
  • GILTI Inclusion and Deemed Paid FTC
  • Forms 5471, 8992, 1118, and 1120

Day Two – Morning Sessions 10:00 AM – 12:00 PM CST

2A – Section 250 GILTI/FDII Deduction

  • GILTI High-Taxed Election
  • Deduction Eligible Income (“DEI”)
  • Foreign Derived Deduction Eligible Income ((“FD-DEI”)
  • Impact of Section 163(j)
  • Section 250 Deduction and limitations
  • 163(j) Group Election
  • Reg. Section 1.861-8 et al
    • Interest Expense, R&E, Stewardship, and Other Deductions
  • Forms 8990, 8992, and 8993

Break – 10:50 – 11:00 AM

2B – Foreign Tax Credit

  • Passive, General, GILTI and Branch Baskets
  • Section 250 and 861-8 Interplay
  • Section 250 Exclusion Percentages
  • R&E Exclusive Apportionment
  • Section 245A Category and the Section 904(b)(4) Adjustment
  • Form 1118

Day Two Afternoon Session 2 PM – 4 PM CST

2C – Global Tax Modeling and Planning

  • Entity Classification
  • Allocation and Apportionment
  • Tax Elections
  • Transfer Pricing Planning
  • Repatriation Analysis

Break – 2:50 – 3:00 PM

2D – Capstone and Completion Certificates

  • Late Breaking News
  • Case Study Overview
  • Calculations and Reports
  • International Tax Forms
  • Q&A

Questions?

For additional information, including regarding program cancellation policies, contact Forte at alavigne@forteintax.com or complete the form below.

If you have concerns or would like information regarding CPE credit, contact BKD at training@bkd.com or 800.472.2745. Click here to read the CPE FAQ.

BKD, LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.