Agenda

CARES Act
– Impact of expanded carryback rules (TPC)
– Section 965 transition tax implications (Forte)
– New Section 163(j) options (TPC)

GILTI High-Tax Exclusion
– Winners and Losers (Forte)
– Applicability for Amended Returns (Forte)
– Making the Election (TPC)

Final Foreign Tax Credit Allocation and Apportionment Regulations
– Interest Expense and Asset Characterization (Forte)
– Research and Experimental Deductions (Forte)
– New Asset Base for Stewardship (TPC)

The instructors will provide specific citations to the new rules and demonstrate the calculation logic by guiding the participants through quantitative examples included in Treasury Regulations. The session will include an integrated Case Study using VantagePoint™ to reinforce the learning objectives and to demonstrate how the various provisions interrelate.

Impact on the GILTI High-tax Exclusion and other elections

VantagePoint Case Study