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Corporate Tax Update Related to U.S. International Tax Reform under the Tax Cuts and Jobs Act (TCJA)

Date: Friday, April 26, 2019
Time: 1:00 - 2:30 pm EST

Sponsored by Lorman Education Services


Registration - Live Webinar Only: $219.00

Registration - Live Webinar Plus CD Recording: $288.00

 

Gain a better understanding of the major new international tax provisions related to the TCJA.

Many corporate tax practitioners must manage the implications of the international tax provisions created under the Tax Cut and Jobs Act (TCJA) that was signed into law on December 22nd, 2017.

With the one-time transition tax still in recent memory, practitioners must now contend with the new world of U.S. territorial tax of foreign income with an alphabet soup of new guardrails such as FDII, GILTI, and BEAT.

This topic will briefly identify the significant new U.S. international tax provisions, their interaction with the pre-legislation international provisions and how to calculate U.S. Federal tax on foreign income. Tax planning opportunities and practical tips will also be briefly mentioned in the material.

Learning Objectives:

  • You will be able to identify and define the major new international tax provisions related to the TCJA.
  • You will be able to recognize the issues related to the interaction of the pre-TCJA provisions and the new international tax provisions.
  • You will be able to discuss how to calculate the companies international tax liability for 2018 and going forward.
  • You will be able to recognize opportunities to reduce international taxes going forward.
This Live Webinar Covers These Hot Issues

New International Tax Provisions Created Under TCJA

  • Foreign Dividend Exemption
  • Foreign-Derived Intangible Income (FDII)
  • Global Intangible Low-Taxed Income (GILTI)
  • Base Erosion and Anti-Abuse Tax (BEAT)

Remaining Pre-TCJA Provisions

  • Foreign Tax Credits
  • IRC Section 861 Allocations
  • Calculating E&P
  • Subpart F
  • IC-DISC

Putting It All Together

  • Examples of How to Calculate International Tax Under the TCJA
  • New Forms
  • Projecting Future Tax Liabilities

Credit Information (Sponsored by Lorman Education Services):

  • CLE
  • CPE
  • AIPB
  • NASBA
  • Enrolled Agents

For Detailed Credit Information page click here

Only registered attendee will receive continuing education credit.

Faculty

Ryan Gaglio, Stradling Yocca Carlson & Rauth, P.C.

  • Attorney with Stradling Yocca Carlson & Rauth, P.C.
  • Focuses on tax planning, tax controversy and transactional matters
  • Advises clients on the federal, state and local tax consequences of mergers and acquisitions, bankruptcies and workouts, executive compensation, as well as tax planning for inbound and outbound transactions, intercompany transfer pricing, foreign currency transactions, and other international tax matters
  • Published several articles and is the co-editor of a comprehensive tax treatise, Taxation of Securities Transactions “Overlooked Impact of Health Care Reform,” Daily Journal (August 31, 2012)
  • J.D. degree, Yale Law School; B.A. degree, Columbia College
  • Can be contacted at 949-725-4042 or RGaglio@SYCR.com

John P. Garcia, CPA, M.B.A., Corporate Tax Advisors

  • Chief tax officer for a multinational consumer products company based in Southern California
  • Recently implemented a global corporate organization restructure in response to the TCJA
  • More than 25 years of experience providing services to major multi-national corporations such as Billabong, Nixon, Targus, Marriott, Dial, Henkel, Brandman University, The University of Phoenix, and CPE, Inc.
  • He conducts regular seminars and workshops on Accounting for Income Taxes – ASC 740/FAS 109; International Taxation; State and Local Taxation; and Uncertain Tax Positions – FIN 48 and Transfer Pricing
  • Wrote the SRR Journal, How to Properly Capitalize Subsidiaries Without Getting Ensnared in the Earnings-Stripping Rules, Fall 2016; California CPA magazine, An Integrated Database Solution to Global Withholding Compliance, June 2013; and Thomson Reuters - Corporate Taxation, Green Corporate Tax Incentives-Wind Technologies, December 2009
  • Member of Arizona Society of CPAs and AICPA
  • M.B.A. degree in international business, University of Phoenix; B.S. degree in accounting and finance, University of Maryland College Park
  • Can be contacted at 877-728-1400 or john.garcia@cpa.com

(Not available outside the US)