Join Us at the 2021 TEI Midyear Conference
Special Offer for TEI Members
We will waive the first-year license fee for the International Tax Form Module (e-fileable forms) for all new VantagePoint licensees.
Expires May 31, 2021.
Regulatory Update – FTC/GILTI/FDII – Technical Issues and Modeling Considerations
March 24th Presentation @ 3:45pm EDT + Vendor Booth (3/21-3/24)
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.