Past Events

Past Events

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.


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


September 2, 2021 | Webinar
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International Tax Boot Camp 2.0


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:

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

Modeling Global & US International Tax Proposals

  • OECD Pillars One & Two
  • Biden Administration Proposals
  • Senator Wyden Proposals

Register Here

June 9-10, 2021 | Webinar Course
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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

1:00pm-2:50pm EST (10:00am-11:50am PST)


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

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


June 8, 2021 |
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Chicago Tax Club: International Tax Compliance Update and Modeling Scenarios

Hosted by Forte International Tax, LLC
Co-hosted by True Partners Consulting, LLC

Mark Gasbarra, National Managing Director, Forte
Alexis Bergman, Director, TPC

This session focuses on the latest international tax compliance requirements and time-sensitive modeling scenarios.

• Key aspects of the final GILTI, FDII and FTC regulations required in preparing 2020 tax returns.
• Significant changes to international tax compliance Forms including 5471, 8992, 8993 and 1118.
• Modeling the GILTI high-tax exclusion and Biden/Wyden proposals
The session includes numeric examples drawn from the Treasury Regulations as well as a fully integrated Case Study to reinforce the learning objectives.
June 2, 2021 | Online
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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

May 24-26, 2021 | Virtual Conference
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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

May 5-7, 2021 | Online
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Marcus Evans Webinar

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


  • 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

May 4, 2021 |
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TEI 2021 Midyear Conference


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

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


  • 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.

March 22-25, 2021 | Washington, D.C.
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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

March 8-12, 2021 | Webinar Course
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International Tax Compliance – What’s New in the 2020 Form Set

*Complimentary Winter Webinar Series*

Forms 1118, 5471, 8992, and more.

February 23, 2021 | Webinar 10:00 AM CST
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Virtual 2021 TCPI Symposium

Annual Tax Policy & Practice Symposium

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

February 10-12, 2021 |
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Asset Characterization – Impact on Interest Expense and Stewardship

*Complimentary Winter Webinar Series*

Modified Gross Income Method
Treas. Reg. 1.861-13

February 4, 2021 | Webinar 10:00 AM CST
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2020 Highlights – International Tax Legislation and Regulations

*Complimentary Winter Webinar Series*

GILTI High-tax Exclusion
Final FTC Regulations

January 14, 2021 | Webinar 10:00 AM CST
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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.

December 3, 2020 | Webinar 10:00 AM CST
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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
November 19, 2020 | Webinar 10:00 AM CST
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Stafford Webinar: IC-DISC Strategies

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

Tuesday, November 10, 2020
1:00pm-2:50pm EST (10:00am-11:50am PST)


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

Randall Janiczek, CPA
Plante & Moran

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

November 10, 2020 | Webinar 1:00 PM CDT
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Understanding & Modeling the GILTI High-Tax Election

*Complimentary Fall Webinar Series*


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

November 5, 2020 | Webinar 10:00 AM CST
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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”



October 26-28, 2020 | Virtual
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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


May 18-20, 2020 | Virtual
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NEW: International Tax Bootcamp Registration

Registration opens March 1st.

April 30-1, 2020 | Webinar Course
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2020 TEI 70th Midyear Conference – CANCELLED

Sponsor & Presenter:

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

“Strategic Global Tax Modeling – Tools & Techniques”

March 22-25, 2020 | Washington, D.C.
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2020 TEI Tax & Tax Technology Seminar


February 24-26, 2020 | Scottsdale Plaza Hotel - Scottsdale, AZ
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TCPI Annual Symposium

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

Sponsor, Booth 8

February 13-14, 2020 | Washington, DC
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MAPI Fall 2019 Tax Council Meeting

November 14-15, 2019 | Chicago, IL
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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

September 24, 2019 | Webinar | 1:00pm-2:30pm EDT
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2019 Association for Computers and Taxation (ACT) Annual Conference: Corporate Tax Automation

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

May 20-22, 2019 | Clearwater Beach, FL
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CorpTax University: ASC 740 Accounting For Income Taxes

U.S. Foreign Income Tax and Manufacturing Credits

May 16-17, 2019 | Plano, TX
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Tax Executives Institute (TEI)’s 69th Midyear Conference

GILTI/FDII/FTC/BEAT – Global Tax Integration

March 31-3, 2019 | Washington, DC
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Tax Executives Institute (TEI) Tax and Tax Technology Seminar

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

February 26-27, 2019 | San Mateo, CA
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CorpTax University Training: ASC 740 Accounting for Income Taxes Training

Presentation: U.S. Foreign Income Tax Credit

December 6-7, 2018 | Plano, TX

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.


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.

August 21, 2018 | Webinar 1:00 PM CDT
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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

May 17, 2018 | Chicago, IL
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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

February 15-16, 2018 | Washington, D.C.
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BKR International: International Tax Committee Telemeeting

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

January 9, 2018 | Webinar
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BKR International: Manufacturing Committee Telemeeting

Implementing Tax Reform Proposals for Closely Held Manufacturers

December 14, 2017 | Webinar
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Strafford Webinar: IC-DISC Strategies


October 5, 2017 | 1:00pm-2:50pm EDT/10:00am-11:50am PDT Webinar
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ACT Webinar

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

August 8, 2017 | Webinar 1:00 PM CDT
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