Events

TEI 76th Annual Conference

Sponsor & Presenter

“Modeling Potential Impacts of Legislation and Planning Alternatives”
Tuesday, 10/26/21 2-3 PM EDT Session

Presenters:

Katrina Welch, Gordon Food Service, Moderator
Mark Gasbarra, National Managing Director, Forte International Tax
Alexis Bergman, International Tax Director, True Partners Consulting
George Salis, Principal Economist & Tax Policy Advisor, Vertex

Session Description:

As tax regimes have gotten increasingly complex and integrated so too has the critically important task of modeling their financial impacts.  Hard lessons learned in late-night modeling sessions concerning TCJA planning and implementation spurred significant interest among TEI members seeking a better way to design and build tax models.  This session brings together a diverse group of leading tax and technology professionals to share experiences, offer insights and inform participants of advances in building financial models.  Our panelists will engage in an interactive dialogue, covering topics, such as situations in which tax models are useful and how decision-makers use them; different approaches for creating tax models and when to use them; how and when tax modeling should be automated; decision-points to consider when deciding upon a modeling approach; and resources for tax modeling.

Learning Objectives:

At the conclusion of this course, participants should:

• Understand how tax models can be useful for decision-making and when to apply them;
• Be aware of different approaches for creating tax models and when to use the different approaches;
• Understand how and when tax modeling should be automated;
• Identify decision-points to consider when deciding upon a modeling approach;
• Be aware of different resources for tax modeling.

International Tax Update: Repatriation Modeling Webinar

Repatriation Modeling Webinar
Special 3-Hour Session
December 8, 2021
1:00 PM – 4:00 PM Central Time

The Tax Cuts and Jobs Act (“TCJA”) dramatically changed the U.S. income tax treatment of the repatriation of foreign earnings. Now, even though IRC Section 245A allows a 100% Dividends Received Deduction (“DRD”) on dividend remittances to corporate shareholders, much of those earnings will have already been subject to U.S. income tax under either the GILTI or Subpart F regime. As a result, many distributions will be out of previously taxed earnings and profits (“PTEP”).

In this session, special attention is paid to the long-established distribution ordering rules prescribed by IRC Section 959 and the Treasury Regulations thereunder. We also explain how those rules have been modified as a result of the Section 965 transition tax and the creation of multiple PTEP accounts and the priority given to Section 965 PTEP accounts within each of the Section 959 layers. PTEP distributions can result in significant foreign exchange gains and losses, and foreign tax credits may be allowed on any additional foreign taxes incurred on PTEP distributions, subject to complex requirements.

During this webinar we will walk participants through the impact of these rules, both by an analysis of the regulation examples, as well as performing how-to-model calculations using Forte’s VantagePoint software.

Learning Objectives:
Understand the distribution ordering rules outlined in IRC Section 959 and the special adjustments relating to Section 965 PTEP Accounts.
Understand how additional income taxes paid on previously taxed income are available for foreign tax credit purposes.
Understand the importance of repatriation modeling for income tax provision purposes.
Discuss how each of the tax requirements is reported on the related international tax forms.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Three (3)

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