Past Events

Marcus Evans Tax Officers Online Summit 2021

TEI 2021 Midyear Conference

Sponsor

Presenting
Regulatory Update – FTC/GILTI/FDII – Technical Issues and Modeling Considerations

View Agenda

Moderator:

Susan L. Curley, Ingram Industries, Vice Chair, TEI’s U.S. International Tax Committee

Speakers:

• Michael J. Caballero, Covington & Burling LLP
• Mark Gasbarra, Forte International Tax LLC
• Adam S. Halpern, Fenwick & West LLP

The TCJA and subsequent administrative guidance continues to result in unexpected and sometimes surprising outcomes for multinational taxpayers’ tax planning and modeling, reaching in some cases counterintuitive results and upsetting old “rules of thumb.” This session will provide an update on the latest in regulatory and other guidance with respect to the worldwide allocation of interest expense, foreign tax credit, sourcing rules, new capitalization rules, and show the complex modeling necessary to produce predictable results under the TCJA’s GILTI and FDII regimes.

Learning Objectives: After this session, participants will be able to: (1) understand recent U.S. international tax regulatory changes; (2) assess the impact of such changes on their employers’ business operations; and (3) describe the factors that should be accounted for when modeling tax outcomes under the TCJA.

2nd Annual International Tax Boot Camp

For more in-depth training, we invite you to attend our 2nd Annual International Tax Boot Camp Training.

Topics Covered:

U.S. International Tax Compliance Calculations
Transfer Pricing and Country-by-Country Reporting
ASE 740 Tax Provision Analysis
Tax Attributes and Repatriation Planning
Update on 2020 International Tax Forms

Register Here

International Tax Compliance – What’s New in the 2020 Form Set

*Complimentary Winter Webinar Series*

Forms 1118, 5471, 8992, and more.

Virtual 2021 TCPI Symposium

Annual Tax Policy & Practice Symposium

“Tax in a Time of Global Disruption: The Future Accelerated & Transformed”

Asset Characterization – Impact on Interest Expense and Stewardship

*Complimentary Winter Webinar Series*

Modified Gross Income Method
Treas. Reg. 1.861-13

2020 Highlights – International Tax Legislation and Regulations

*Complimentary Winter Webinar Series*

CARES Act
GILTI High-tax Exclusion
Final FTC Regulations

Repatriation Analysis | PTEP & Tax Basis

*Complimentary Fall Webinar Series*

Participants will understand the impact of foreign earnings and profits, including previously tax earnings and profits, and tax basis on the following areas:

·       Repatriation analysis

·       ASC 740 income tax provision

·       Treatment of additional taxes paid on PTEP distributions and the Excess Limitation Account

·       Characterization of CFC Stock under Treas. Reg. § 1.861-13 for apportioning interest expense and stewardship

·       Impact of the GILTI High-Tax Exclusion

The latest tax technical guidance, numerical Treas. Reg. Examples, and an integrated VantagePoint™  Case Study will be provided.

Understanding & Modeling the CARES Act

*Complimentary Fall Webinar Series*

Practical guidance in understanding and Modeling the CARES Act focusing on the international tax aspects, including:

• NOL Carryback and related provisions
• Interplay between NOL, Section 965, GILTI, FDDI, FTC and BEAT
• Expanded Section 163(j) options for 2019 and 2020 tax years
• Impact on the GILTI High-tax Exclusion and other elections
• VantagePoint Case Study

Stafford Webinar: IC-DISC Strategies

“IC-DISC Strategies: Mastering Complex Challenges”
A live 110-minute CPE webinar with interactive Q&A

Panelists:

Mark C. Gasbarra, CPA
National Managing Director
Forte International Tax

Randall Janiczek, CPA
Partner
Plante & Moran

Robert J. (Rob) Misey, Jr.
Shareholder
Reinhart Boerner Van Deuren

Understanding & Modeling the GILTI High-Tax Election

*Complimentary Fall Webinar Series*

Panelists:

Mark C. Gasbarra, CPA
National Managing Director
Forte International Tax

Lester Fuwa
Managing Director
Forte International Tax

Scott Bozzi
International Tax Consultant 
Forte International Tax

2020 TEI 75th Annual Virtual Conference

Sponsor & Presenter:

Presentation at 5:00 pm-6:30 pm Tuesday October 27th

“International Tax Modeling Primer: BEAT, GILTI, 163(j), FDII, FTC”

Virtual Booth will be open the entire conference from 12:00 pm October 26th through 12:00 pm on October 28th.

2020 ACT Virtual Conference

Sponsor & Presenter:

“International Tax Transformation & CAREs Act” @ 9:10 am CDT Tuesday May 19th

Vendor Expo  @ 6:15-7:00 pm CDT Tuesday May 19th

NEW: International Tax Bootcamp Registration

Registration opens March 1st.

2020 TEI 70th Midyear Conference – CANCELLED

Sponsor & Presenter:

Class at 11:30-12:30 am Tuesday March 24th

“Strategic Global Tax Modeling – Tools & Techniques”

48th Annual Conference of the USA Branch of the International Fiscal Association

Attendee

2020 TEI Tax & Tax Technology Seminar

Speaker

TCPI Annual Symposium

Hindsight is 2020: What the TCJA and Global Developments Tell Us About the Future of Tax

Sponsor, Booth 8

2020 Tax Legislative and Regulatory Update Conference and Reception with DC Bar

Sponsor

32nd Annual Institute on Current Issues in International Taxation

Attendee

MAPI Fall 2019 Tax Council Meeting

Marcus Evans 2019 Tax Officers Summit

TEI Annual Conference: Tax Department Transformation: From Technology to the TCJA

IC-DISC & FDII Strafford Webinar: U.S. Export Incentives Post-Tax Reform, Pricing Commissions, and Structuring Corporate Entities

Maximizing Tax Savings, Pass-Through Entities vs. C Corporations, Distributor Companies, and Alternative Ownership Structures

A live 90-minute premium CLE/CPE webinar with interactive Q&A

2019 Association for Computers and Taxation (ACT) Annual Conference: Corporate Tax Automation

Presenter & Sponsor
International Tax Automation in a Post-Tax Reform World

CorpTax University: ASC 740 Accounting For Income Taxes

Presenter
U.S. Foreign Income Tax and Manufacturing Credits

McDermott Will & Emery’s 2nd Annual Tax Symposium

Attendee

Tax Executive Institute (TEI) Minnesota Chapter’s 36th Annual President’s Seminar

Sponsor

Tax Executives Institute (TEI)’s 69th Midyear Conference

GILTI/FDII/FTC/BEAT – Global Tax Integration
Presenter

Tax Executives Institute (TEI) Tax and Tax Technology Seminar

GILTI/FDII/FTC/BEAT – Global Tax Integration
Presenter
Client Panelist: Texas Instruments – Vera Cretcher
Firm/Vendor Speaker: Forte International – Mark Gasbarra & Thomson Reuters (Orbitax team)
Moderator: Sandhya Edupuganty

47th Annual Conference of the USA Branch of the International Fiscal Association

Exhibitor & Attendee

Tax Council Policy Institute (TCPI): The evolving boundaries of tax

Sponsor

Tax Executives Institute, Inc. (TEI) New York Chapter 55th Annual Tax Symposium

Sponsor

CorpTax University Training: ASC 740 Accounting for Income Taxes Training

Presentation: U.S. Foreign Income Tax Credit

Association for Computers and Taxation (ACT) Webinar: GILTI, FDII, FTC and the Impact of 861-8

This webinar uses an integrated case study to illustrate the impact of 861-8 on Sec. 965, GILTI, FDII, and FTC.

Description

The allocation and apportionment of deductions under Treas. Reg. Section 1.861-8 is a critical factor in calculating the following statutory provisions:

• Subpart F Income;
• Global Intangible Low-taxed Income (“GILTI”);
• DISC Taxable Income;
• Domestic Production Activities Deduction;
• Foreign Derived Intangible Income (“FDII”); and
• Foreign Tax Credit Limitations.

This session focuses on the application of the 1.861-8 regulations using an integrated Case Study to demonstrate the impact on Subpart F, GILTI, FDII, and the separate FTC limitations.  The Case emphasizes the need to perform “what-if” modeling using alternative methods, especially considering the uncertainty surrounding the impact of 1.861-8 on the GILTI deduction.

Speaker Bios

Mark Gasbarra, National Managing Director, Forte International Tax
With over 30 years of industry experience, Mark has helped many of the country’s most successful enterprises implement all aspects of international taxation. A hallmark of Mark’s career has been leveraging technology to improve tax department performance. Prior to founding Forte International Tax, Mark held leadership positions at PwC, Ernst & Young, and CliftonLarsonAllen. Mark leads the firm on its mission of achieving global tax minimization through process efficiency.

Sandhya Edupuganty, Corporate Tax, Texas Instruments Incorporated
Sandhya has over 30 years of tax experience in multinational corporations as well at Big 4 accounting firms in direct and indirect tax, federal, state and international tax and tax compliance and tax accounting roles. She has a bachelors in commerce from St Francis College, India and a Masters in Accounting (specialization in tax) from University of Alabama, Birmingham. Building on tax technical skills, she has focused the second half of her career on streamlining processes to reduce risk through tax technology. She is an active member of Tax Executives Institute and ACT.

Strafford Webinar: IC-DISC and FDII: U.S. Export Incentives Post-Tax Reform, Pricing Commissions and Structuring Corporate Entities

Presenter

2018 Association for Computers and Taxation (ACT) Annual Conference

Sponsor

Illinois Chamber of Commerce’s 4th Annual Export Conference: Global is Local: Developing a 21st Century Trade Policy That Works for Illinois

Presenter and Panel Sponsor
Presentation: Tax Reform, Leveling the Playing Field and Export Tax Incentives

Tax Council Policy Institute’s (TCPI) 19th Annual Tax Policy & Practice Symposium

“Disruption and opportunity in the era of global tax transformation”
Exhibitor (Table 11

BKR International: International Tax Committee Telemeeting

Presenter
U.S. International Tax Reform: Leveling The Playing Field

BKR International: Manufacturing Committee Telemeeting

Presenter
Implementing Tax Reform Proposals for Closely Held Manufacturers

BKR International: International Tax (Americas) Committee Telemeeting

Update on IC-DISC

Strafford Webinar: IC-DISC Strategies

Presenter

ACT Webinar

Leveraging Technology to Deliver Tax Savings: How to Optimize the Domestic Production Activities Deduction & FTC Utilization