Past Events

Webinar: 2023 International Tax Compliance Update

Presented by:
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

Webinar: IC-DISC and FDII Optimization

Presented by:
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

Webinar: Foreign Parented Multinational Groups

Presented by:
David Merrick, JD, LLM, Forte International Tax, LLC
Mark Gasbarra, CPA, Forte International Tax, LLC

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

Global Tax Optimization Boot Camp

2024 Annual Conference International Fiscal Association (IFA)

Sponsor & Presenter

Register

2024 74rd TEI Midyear Conference

Sponsor & Presenter

Pillar Two Update & Implementation

Tuesday, 3/19/2024 | 11:15 AM – 12:15 PM EDT.

Register

Forvis Pillar Two Boot Camp: Part 2

Join Forvis and delve deeper into the technical nuances associated with Pillar Two’s global minimum tax. In this informative session, we’ll share how the Pillar Two global minimum tax works, the computation of the GloBE tax mechanics and the requisite adjustments needed, the various safe harbor tests released by the OECD, and the GloBE information return. In addition, these topics will be integrated into a practical case study for participants to follow.

Learning Objectives:

• Describe the general framework of the Pillar Two global minimum tax as enumerated by the OECD Inclusive Framework and subsequent administrative guidance.
• Recall the technical nuances surrounding GloBE adjustments.
• Discuss the technical aspects of the Pillar Two model rules.

Register 

Webinar: Repatriation Planning and APB23

Presented by:

Phil Laminack, CPA, FORVIS

Chris Clifton, CPA, FORVIS

Alexis Bergman, CPA, Baker Tilly

David Merrick, JD, LLM, Forte International Tax, LLC

Mark Gasbarra, CPA, Forte International Tax, LLC

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1) Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

GloBE Meets GILTI: Ready, Set, Go!

Presented by:

John Karasek, JD, LLM, McDermott Will Emery

David Merrick, JD, LLM, Forte International Tax, LLC

Mark Gasbarra, CPA, Forte International Tax, LLC

This session covers IRS Notice 2023-80 including specific rules for the calculation interplay between Pillar Two and GILTI.

Specific learning objectives participants will derive from this session include:

1. Understanding how Pillar Two Qualified Domestic Top-up Taxes (QDMTT) impact the calculation of GILTI, including its impact on the GILTI High-Tax Exclusion
2. Understanding how QDMTTs impact the Subpart F High-tax Exception.
3. Understanding the definition of a Final Top-up Tax and the U.S. effect on members within and without the MNE Group
4. Understanding the interaction between the U.S. Dual Consolidated Loss Rules with the GloBE Rules
5. Understanding the Extension and Modification of Temporary Relief of the 2002 Foreign Tax Credit Regulations

A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

CLE credit is pending in CA, IL, NY (where McDermott is an approved CLE provider). A Uniform Certificate of Attendance will be made available to participants requesting CLE credit in all other Jurisdictions; which may be used to self-apply for CLE credit in their state of admission.

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

Strafford Webinar: IC-DISC Strategies: Mastering the Complex Operational Challenges

A live 50-minute premium CPE webinar.

The tax savings available for exporters through an IC-DISC (interest charge-domestic international sales corporation) remain a significant incentive for businesses and their owners. Accounting professionals and corporate tax specialists must prepare for the burdensome tax and accounting challenges that come into play after implementing IC-DISCs.

Tax planning involving an IC-DISC requires more intensive review with the currently qualified business income deduction (QBID) for pass-through entities and the Section 250 deduction for FDII available to C corporations. These new demands add to higher-level compliance challenges for advisers to businesses.

Perspectives from advisers with years of experience in IC-DISC structures will help you deal with its most vexing tax challenges, including strategies for handling critical day-to-day operational aspects, calculating commissions, anticipating IRS audit risk areas, improving liquidity for the parent and shareholders, and identifying optimal approaches to complicated computational problems.

Our panel will prepare accounting professionals and tax advisers to fully leverage the tax benefits of IC-DISC formation. The panel will review and explain the key strategic steps for day-to-day aspects of running an IC-DISC, including calculating commissions, spotting IRS audit risks, and tackling the complex computations required. The panel will outline critical IC-DISC tax planning opportunities, including using the best DISC ownership structures to maximize DISC benefits.

We will guide you through issues including:

• Maximizing unique IC-DISC tax benefits such as the tax benefits from different shareholder structures
• Understanding tax liability for DISC structures and the QBID
• Managing day-to-day operational aspects of using an IC-DISC
• Improving liquidity for the parent and shareholders: steps to consider
• Overcoming computational challenges

After our presentations, we will engage in a live question and answer session with participants so we can answer your questions about these important issues directly.

Pillar Two Boot Camp + Interactive Case Study

EARLY BIRD REGISTRATION IS OPEN THROUGH OCTOBER 20th

WEEK 1

Technical Sessions  – 6 Modules M/W/F at 10 AM and 2 PM CDT – 9 CPE Hours

1. OECD Guidance and Legislative Update
   1. Overview of OECD Guidance
   2. Jurisdictional Update
   3. Subject to Tax Rule (STTR)
2. Top-Up Tax and Tax Accounting
   1. Operational Rules
   2. GloBE Income Adjustments
   3. Tax Adjustments
3. Charging Provisions
   1. Qualified Domestic Top-up Tax (QDMTT)
   2. Income Inclusion Rule (IIR)
   3. Under Taxed Profit Rule (UTPR)
4. Pillar Two Safe Harbours and Elections
   1. Safe Harbours
   2. Elections
   3. Penalty Relief
5. Interplay with U.S. Tax Calculations
   1. S. Ultimate Parent Entity (UPE)
   2. Foreign UPE with U.S. Sandwich Structure
   3. UPTR Safe Harbour
   4. Corporate Alternative Minimum Tax (CAMT)
6. GloBE Information Return
   1. Coordination Pillar Two Operational Rules
   2. Simplified Filing Requirements
   3. Surrogate Entity Jurisdiction

WEEK 2

Interactive Case Study – 5 hours of CPE

Participants work through a live fully-integrated Pillar Two Case Study in 5 sessions.

• Case Study Introduction and Financial Accounting Net Income or Loss
  • Legal Structure
  • Jurisdictional Tax Attributes
  • Financial Accounting Net Income or Loss (FANIL)
  • Chart-of-Accounts
  • Trial Balances
• Tax Purposes, Adjustments and Country-by-Country Report
  • Tax Purposes
  • Adjustments
  • Country-by-Country Report
  • IRS Form 8975
• U.S. Tax Calculations and Pillar Two Reports
  • Operational Rules
  • GILTI, FDII and FTC
  • Transitional Safe Harbour Report
  • Pillar Two Report
• GloBE Information Return
  • MNE Group Information
  • Jurisdictional Safe Harbours and Exclusions
  • GloBE Computations
• Wrap-Up and Final Polling and Q&A
  • Jurisdictional Attributes
  • FANIL and Adjustments
  • S. Tax Calculations
  • Pillar Two Reports
  • GloBE Computations

Up to 14 CPE

This session covers OECD Guidance including the following two OECD documents published as of July 13, 2023:

• https://www.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-july-2023.pdf
• https://www.oecd.org/tax/beps/globe-information-return-pillar-two.pdf

Specific learning objectives participants will derive from this session include:

• Understanding the new Qualified Domestic Top-Up Tax (QDMTT) Safe Harbour
• Understanding the Transitional UTPR Safe Harbour for Jurisdictions subject to a Tax Rate of at least twenty percent
• Understanding the new guidance on tax credits including transferable credits
• Understanding the final changes to the GloBE Information Return (GIR)

A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Up to Fourteen (14)
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Refunds are not available, except for duplicative registrations.

2023 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.

Register

2023 75th Anniversary Annual Conference

Sponsor & Presenter

Webinar: Preparing for the GloBE Information Return, Part III

New Pillar Two Updates – Final GloBE Information Return (GIR)

Tuesday, August 1st – 2:00 PM CDT
Up to 1 CPE

This session covers OECD Guidance including the following two OECD documents published as of July 13, 2023:

• https://www.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-july-2023.pdf
• https://www.oecd.org/tax/beps/globe-information-return-pillar-two.pdf

Specific learning objectives participants will derive from this session include:

• Understanding the new Qualified Domestic Top-Up Tax (QDMTT) Safe Harbour
• Understanding the Transitional UTPR Safe Harbour for Jurisdictions subject to a Tax Rate of at least twenty percent
• Understanding the new guidance on tax credits including transferable credits
• Understanding the final changes to the GloBE Information Return (GIR)

A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

Webinar: Preparing for the GloBE Information Return, Part II

Understanding Pillar Two Calculations and the GloBE Information Return: Part II

This session provides practical guidance on what you need to know in order to effectively prepare for the Pillar Two Global Minimum Tax (GMT). The session outlines the specific operational rules necessary to calculate GMT related Top-Up Taxes as well as the Transitional CbCR Safe-Harbour determinations. The components of the GloBE Information Return (GIR) are explained, including the specific data points necessary for tax administrations to evaluate the correctness of a Constituent Entity’s (CE) GloBE tax liability. A brief Case Study is presented to reinforce the calculation methodology including the interplay of Pillar Two with the GILTI tax calculations.

Learning Objectives
• Participants will learn the specific operational rules required to calculate potential Top-Up taxes under Pillar Two.
• Participants will understand the differences between the Pillar Two computations and those provided under the Transitional CbCR Safe Harbor provisions.
• Participants will understand how the Pillar Two computational determinations are presented in the GloBE Information Return (GIR).

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

2023 ACT Annual Tax Technology Conference

Sponsor & Presenter
“GloBE Meets GILTI – integrated modeling scenarios with and without the GILTI high-tax exclusion and CAMT”
May 24th 1:30pm -2:30pm ET

Register

TCPI: Fostering Sound & Durable Tax Policy: The Vital Role of Business

Sponsor & Exhibitor 

Join us at the 24th Annual Tax Policy & Practice Symposium as we examine the competing forces and the role of business in shaping the policy response to growing challenges. Over our two days together, leaders of the tax community will consider:

• The budget facts and options to bring spending and revenues into balance
• The role of income taxes and alternative tax bases in meeting governments’ revenue needs, and the political prospects for change
• The future of global tax policy whether implementation of the OECD’s two-pillar agreement fails or succeeds
• The implications of the increasing focus on ESG reporting and tax transparency
• Prospects for effectively channeling tax administration resources and promoting comprehensive cross-border dispute resolution for competing claims of jurisdiction to tax business profits

Register

2023 TEI Tax Technology Seminar

Sponsor & Presenter
“Global Transparency and International Automation Outlook – Leveraging Automation to Keep Pace with a Changing World”
Tuesday, April 25
10:15 am – 11:15 am CDT

Register

Webinar: Preparing for the GloBE Information Return

This session analyzes the underlying data points and calculations necessary to comply with Pillar Two.  

2023 73rd TEI Midyear Conference

Sponsor & Presenter
”Gathering, Wrangling and Utilizing Foreign Entity Data – How “Mature” Is Your Process?”
March 21st 11:00am -12:00pm ET

Register

4th Annual | International Tax Boot Camp | Forte + FORVIS + Baker Tilly

UPCOMING ONLINE WORKSHOP
February 21st – March 9th 
Business Days 10:00am-12:00pm CT & 2:00-4:00pm CT
-Up to 24 CPE-
-2 per Module-

4th Annual
International Tax Boot Camp

VIEW PROGRAM & REGISTER

Join Forte International Tax, Forvis, and BakerTilly panelists for our Fourth Annual International Tax Boot Camp.

This workshop is designed to keep international tax professionals up to date with the latest provision and compliance requirements and the impact of proposed global tax initiatives, including Pillar Two.

The live virtual program will cover 2022 compliance requirements and late breaking developments for understanding and modeling outbound international tax calculations.

Up to 24 CPE credits will be provided for live registrants and all recordings will be available for replay.

Highlights
Latest International Tax Technical Content

• Practical, immediately useful knowledge, keeps you you up-to-date on the latest U.S. outbound international tax compliance requirements.
• Insightful tax saving strategies.
• Highly skilled instructors with decades of client-serving experience.
• Learning objectives are reinforced through integrated Case Study examples.

Learning Objectives

Click to learn more about the program and detailed learning objectives by Module.

Pricing

Discounts are available for Early Bird Registrants, as well as for multiple persons by firm.  We encourage your whole team to take advantage of the Group Rate.  Are you a client or past Boot Camp participant? Email us to get an additional discount as a thank you.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Twenty Four (24)

GloBE Meets GILTI Update

GloBE Meets GILTI Update Webinar
Covering the Latest OECD Guidance Released February 1, 2023

This session covers important computational guidance approved by the OECD/G20 Inclusive Framework on BEPS on February 1, 2023. In particular, this guidance provides specific rules on how to allocate income taxes arising under Blended CFC Tax Regimes for purposes of calculating the effective tax rate of Constituent Entities for purposes of the Pillar Two Global Minimum Tax. The guidance approves GILTI as such a regime and allows the GILTI Tax to be allocated to each entity according to a specifically defined allocation key. This session explains the guidance and provides specific numerical examples of its practical application. A Case Study with and without the GILTI high-tax exclusion using Forte’s VantagePoint™ software will also be presented.

Discussion Topics

• Pillar Two Timeline/Update
• Overview of 2/1/2023 Guidance
  • Specific rules with respect to Blended CFC Tax Regime including GILTI
  • QDMTT Rules

Learning Objectives

1. Participants will be gain an understanding of the Feb 1 update of the Pillar Two’s implementation timeline and status.
2. Participants will understand how to allocate the GILTI tax cost for purpose of computing covered taxes for Pillar Two purposes.
3. Participants will learn when a Qualified Domestic Top-Up Tax (QDMTT) will be included in covered taxes for Pillar Two purposes.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

What’s New in VantagePoint 2023

Please join us for a demonstration of the latest VantagePoint enhancements and those soon to be released, including the Corporate Alternative Minimum Tax (“CAMT”) and CAMT FTC.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: None

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

VantagePoint Demo – Integrated Modeling (no CPE)

VantagePoint Demo – Integrated Modeling incl GILTI, FDII, FTC and a look at Pillar Two (no CPE Offered)

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: None

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

Webinar: Repatriation and the APB23 Assertion

Overview of the topics discussed in this webinar:

A – PTEP/245A
B – FX Gains (Losses)
C – Withholding Taxes

Program Field of Study: Taxes

Program Level: Intermediate
# of CPE credits: One (1)

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

2022 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.

Register

2022 77th TEI Annual Conference

Sponsor & Presenter
“GloBE Meets GILTI – Integrated Planning & Modeling Strategies”
Tuesday Oct 25th @ 11:00 AM-12:00 PM

Program

Strafford Webinar: IC-DISC Strategies – Mastering the Complex Operational Challenges

A live 50-minute premium CPE webinar.

The tax savings available for exporters through an IC-DISC (interest charge-domestic international sales corporation) remain a significant incentive for businesses and their owners. Accounting professionals and corporate tax specialists must prepare for the burdensome tax and accounting challenges that come into play after implementing IC-DISCs.

Tax planning involving an IC-DISC requires more intensive review with the currently qualified business income deduction (QBID) for pass-through entities and the Section 250 deduction for FDII available to C corporations. These new demands add to higher-level compliance challenges for advisers to businesses.

Perspectives from advisers with years of experience in IC-DISC structures will help you deal with its most vexing tax challenges, including strategies for handling critical day-to-day operational aspects, calculating commissions, anticipating IRS audit risk areas, improving liquidity for the parent and shareholders, and identifying optimal approaches to complicated computational problems.

Our panel will prepare accounting professionals and tax advisers to fully leverage the tax benefits of IC-DISC formation. The panel will review and explain the key strategic steps for day-to-day aspects of running an IC-DISC, including calculating commissions, spotting IRS audit risks, and tackling the complex computations required. The panel will outline critical IC-DISC tax planning opportunities, including using the best DISC ownership structures to maximize DISC benefits.

We will guide you through issues including:

• Maximizing unique IC-DISC tax benefits such as the tax benefits from different shareholder structures
• Understanding tax liability for DISC structures and the QBID
• Managing day-to-day operational aspects of using an IC-DISC
• Improving liquidity for the parent and shareholders: steps to consider
• Overcoming computational challenges

After our presentations, we will engage in a live question and answer session with participants so we can answer your questions about these important issues directly.

GloBE Meets GILTI – Pillar Two Update

Overview of the topics discussed in this webinar:

A – Latest OECD Guidance and Timeline
B – European Union Perspectives – Pillar II and DSTs
C – USA Landscape
D – Practical Modeling Solutions

Learning Objectives:

1. The participants will understand the latest OECD Pillar II Guidance including the revised implementation timeline.
2. The participants will understand the status of the EU’s acceptance of Pillar II as well as various DSTs.
3. The participants will understand how various USA international tax rules interplay with Pillar II and gain practical insights on potential modeling scenarios.

Program Field of Study: Taxes

Program Level: Intermediate
# of CPE credits: One (1)

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

Webinar: Foreign Tax Credit Regulations (as corrected!) Plus: New Book Minimum Tax AMT FTC

The ABC’s of Fully Integrated International Tax Modeling

Poll Results

Please join Forte International Tax, LLC for our upcoming webinar, “The ABC’s of Fully Integrated International Tax Modeling”

Webinar Description

This session provides an interactive guide to essential international tax modeling scenarios using Forte’s VantagePoint™ software as the quantitative tool. The panelists will demonstrate specific examples throughout the planning, provision, and compliance lifecycle. The demonstration begins with international tax compliance and the resulting tax attributes and sourcing which serve as the foundation for all future modeling. Tax technical citations for the underlying calculations are provided and the Webinar provides one-hour of CPE credit.

Register

2022 IFA Annual Conference

Sponsor

50th Annual Conference of the USA Branch of the International Fiscal Association

Thursday, June 2 and Friday, June 3, 2022

Register

Webinar: International Tax Update New Schedules K-2/K-3

New Schedules K-2 and K-3

Forte BKD Webinar – Tuesday, May 31, 2022

Beginning for 2021 tax years new schedules K-2 and K-3 standardize and very significantly expand the international tax reporting requirements for pass-through entities.

Participants in this webinar should gain a general understanding of the data elements included in the schedules and the mechanics behind completing the schedules.

Instructors:

Chris Clifton, BKD

Mark Gasbarra, Forte International Tax

Joshua Zellerman, BKD

Register 

2022 ACT Annual Conference

Sponsor

2022 TCPI Symposium

Annual Tax Policy & Practice Symposium

“Seeking Stability in the Midst of Global Seismic Shifts”

2022 TEI Tax Technology Seminar

Sponsor

3rd Annual | International Tax Boot Camp | Forte + BKD + TPC

UPCOMING ONLINE WORKSHOP
April 18-27, 2022
Business Days 11:00-1:00pm CT
-Up to 16 CPE-
-2 per Module-

3rd Annual
International Tax Boot Camp

VIEW PROGRAM & REGISTER
Join Forte International Tax, BKD, and TruePartners Consulting for our third annual International Tax Boot Camp | LIVE Online Workshop | April 18-27. The program will cover 2021 compliance requirements and late breaking developments. Up to 16 CPE credits will be provided for live registrants.

In addition to the highlights below, this in-depth presentation will include an update on Pillars One and Two (“GloBE”) including the interplay with the U.S. international tax regime.  Detailed instructions on completing the 2021 international tax forms, including Form 5471 and 1118, will be covered as well as valuable insights on available tax elections, repatriation planning and ASC740 aspects.

Highlights

• 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
• State treatment Foreign Income
• ASC740/APB23

Learning Objectives

Participants will gain understanding of the following:

• Understanding the primary international tax reporting and underlying computational requirements of U.S. Corporations and other U.S. Shareholders with operations outside of the U.S.

• Understanding the most up to date international reporting requirements including Forms 8858, 8865, 8975, 5471 and 1118 as clients are navigating the 2021 tax compliance season.
• Understanding how U.S. international tax attributes are reported for ASC740 purposes.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Sixteen (16)

2022 TEI’s 72nd Hybrid Midyear Conference

Sponsor & Presenter

Wednesday, March 23, 9:45-10:45 am

International Tax  Modeling Update – Challenges and Opportunities

This session provides international tax modeling strategies to deal with increasingly dynamic and complex international tax environment. The panel discusses the latest OECD guidance relatedto Pillars One and Two and how conforming U.S. legislation, including aspects of Build Back Better, may or may not follow. An integrated software model using Forte’s VantagePoint software will be presented.

Program

International Tax Update: Final Foreign Tax Credit Regulations | Part 2

During this webinar our panel will walk participants through the key elements of the Final January 4, 2022 FTC regulations, both by an analysis of the regulation examples, as well as the practical implementation issues.

Learning Objectives:
Participants will gain understanding of the following:
– The net gain requirements
– Attribution vs. Jurisdictional Nexus
– In-lieu-of income tax requirements – Treas. Reg. 1.861-20 allocation of income taxes

Program Field of Study:
Taxes Program Level: Intermediate
# of CPE credits: One (1)

Register

International Tax Update: FTC Regulations

During this webinar our panel will walk participants through the key elements of the Final January 4, 2022 FTC regulations, both by an analysis of the regulation examples, as well as the practical implementation issues.

# of CPE credits: One (1)

VantagePoint 10.0 Release

January 23, 2021 Release Notes Summary:

• APB23 Calculations
  • Chain-by-Chain
  • Rollup of Distributable Reserves
• Enhanced Distribution Logic
  • Pro-rata share Blocks
  • Subs/Own Parameter
• 163(j) CFC Group Election
  • Final consolidation regulations
  • Automatic for 2021 tax years

More detailed Version 10.0 Release Notes will be posted on the VantagePoint Resources Page.

Please contact your support team for further assistance.

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)

Register

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

Register

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

REGISTER

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 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 Tax Officers Online Summit 2021

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