Past Events

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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2021 Marcus Evans Tax Summit

The Tax Officers Summit is an invitation-only, premium Summit bringing leading Chief Tax Officers and innovative suppliers and solution providers together. The Summit’s content is aligned with key tax challenges and interests, relevant market developments, and practical and progressive ideas and strategies adopted by successful pioneers.

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.

Forte Webinar: The GILTI High-Tax Exclusion and Treas. Reg. 861-8

Join Forte September 2nd @10am for a timely webinar on “The GILTI High-Tax Exclusion & Treas. Reg. 861-8” and earn CPE credit.

Summary:

The impact of Treas. Reg. 861-8 regulations at both the CFC and US shareholder level is a major driver on the U.S. tax cost of the GILTI regime.

Significant potential tax savings may be available by electing the GILTI high-tax exclusion but those savings can only be realized through complex modeling exercises including the impact of the CFC stock characterization rules prescribed in Treas. Reg. Section 1.861-13.

In this session, special attention is paid to the modified gross income method of apportioning interest expense at the CFC level, which becomes the basis for characterizing the CFC’s stock basis and PTEP/E&P Bump. This CFC stock characterization in-turn is a key component of the US shareholder’s asset base used for apportioning the US shareholder’s interest expense and stewardship expenses to various categories of foreign source income, including GILTI and income qualifying for the Section 245A 100% dividends received deduction.

During this webinar we will walk participants 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:

– Explain how Treas. Reg. 861-8 regulations impacts the GILTI High Tax Exclusion.

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

– 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: 1

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International Tax Boot Camp 2.0

INTERNATIONAL TAX BOOT CAMP 2.0 
2020 TAX COMPLIANCE UPDATE & MODELING SCENARIOS

For more in-depth training, we invite you to attend our  International Tax Boot Camp 2.0 Training.

CPE CREDITS: Up to 8 CPE credits in the Taxes field of study may be awarded upon verification of participant attendance.

Highlights Include:

Register Here

Strafford Webinar: Tax Considerations of Repatriation

“Tax Considerations of Repatriation: Previously Taxed E&P, Non-PTEP, Return of Capital, Multi-Tiered Distributions”

This webinar will cover repatriation issues for multinational taxpayers. Our panel of foreign tax experts will examine distributions of E&P from PTEP, non-PTEP, and the return of basis and explain the tax considerations and benefits available for each distribution type.

Tuesday, June 8, 2021

Panelists:

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

Patrick J. McCormick, J.D., LL.M
Partner
Culhane Meadows Haughian & Walsh

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Chicago Tax Club: International Tax Compliance Update and Modeling Scenarios

ACT 2021 Virtual Annual Conference

Sponsor & Presenter

International Tax Modeling – Seize the Data and Seize the Day

Wednesday, May 26, 2021 @ 10:45 ET

This session focuses on some of the most critical modeling imperatives in the dynamic world of intentional tax, including global tax policy aimed at the digital economy.  Moving closer to home, the discussion drills into U.S. international modeling including foreign branch vs. controlled foreign corporation comparisons, the whys and wherefores of the GILTI high-tax exclusion, and repatriation planning.  A fully integrated Case Study covering GILTI, FDII and Foreign Tax Credit will be presented.

+ Visit our Vendor Lounge for a chance to win $100 donation for your favorite non-profit and more!

Wednesday, May 26, 2021 @ 10:45 ET

Marcus Evans Tax Officers Online Summit 2021

Marcus Evans Tax Summit

The Tax Officers Online Summit is an invitation-only, premium Summit bringing leading Chief Tax Officers and innovative suppliers and solution providers together. The Summit’s content is aligned with key tax challenges and interests, relevant market developments, and practical and progressive ideas and strategies adopted by successful pioneers

Marcus Evans Webinar

Presenting:
International Tax Modeling: Foreign Branch vs. CFC Subpart F vs. GILTI

Speakers:

• Nancy Loube, VP of Tax, Brunswick Corporation
• Dana Harper, Director, International Tax, Deckers Brands
• Mark Gasbarra, National Managing Partner, Forte International Tax LLC

Register Link

2021 TEI Tax Technology Seminar

Sponsor

Register Link

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