CPE Packages (Incl. Ethics) for Multiple States and Qualifications Available. Price $4/credit - CLICK HERE to view.

Planning for an Uncertain Future in International Taxation

Jonathan Grossberg

Grossberg Continuing Education

Monday, July 26, 2021 | 12:00 PM EDT

  • AFSP
  • CPA (US)
  • EA
  • Oregon Tax Preparer
  • CTEC
  • Maryland Tax Preparer

1 Credit

$10

Subject Area

Taxes

Webinar Qualifies For

1 CPE credit of Taxes for all CPAs

1 CE credit of Federal Tax Update for Enrolled Agents ( IRS Approved : GEHNZ )

1 CE credit of Federal Tax Law Update for California Tax Professionals (CTEC Approved-6273)

1 CE credit of Annual Filing Season program (AFSP)( IRS Approved : GEHNZ )

1 CE credit of Federal Tax Update for Oregon Tax Preparers

1 CE credit of Federal Tax for Maryland Tax Preparers

1 General Educational credit for Tax Professionals / Bookkeepers / Accountants

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Course Description

The proposed and possible upcoming changes in U.S. international taxation stemming from the U.S. Treasury’s recently released General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (the “Green Book”) and the recently signed G7 Finance Ministers and Central Bank Governors Communique (“G7 Communique”).

 

After a proposed increase in the corporate tax rate to 28% that is very likely a non-starter, the Green Book’s second proposal is in an area of high interest for governments across the developed world—imposing a global minimum tax.  The Biden administration would substantially revise the tax on Global Intangible Low-Taxed Income (GILTI) and seek to increase it in four ways.  First, by reducing the deduction for corporate U.S. shareholders under Section 250 for the GILTI inclusion.  Second, by eliminating the provisions that reduce GILTI by a ten percent return on qualified business asset income (QBAI).  Third, by requiring a jurisdiction-by-jurisdiction determination of GILTI rather than a determination of GILTI by netting all net tested CFC income (loss) across all CFCs held by a given U.S. shareholder regardless of the corporate residency of each CFC.  Fourth, by repealing the high tax exemption in the GILTI rules and for Subpart F income.

This online IRS approved CPE/CE course will also discuss another significant change proposed in the Green Book is the strengthening of Section 7874 to prevent inversions.  Inversions are the combination of a domestic entity with a foreign entity with the foreign entity emerging as the parent corporation.  Inversions are executed to escape the United States system of worldwide taxation.  The Green Book proposals would lower the threshold from a split 60/80 percent test to a greater than 50 percent test so that where former shareholders of the U.S. corporation hold greater than 50 percent of the stock of the surviving corporation, the corporation is treated as a domestic corporation for all purposes of the Code.

The Green Book also proposes repealing the deduction for Foreign-Derived Intangible Income (FDII).  The Green Book would also apply principles of Section 338(h)(16) to determine the source and character of any item of income recognized in connection with a direct or indirect disposition of an interest in a specified hybrid entity.

The Green Book would also replace the Base Erosion Anti-Abuse Tax with the Stopping Harmful Inversions and Ending Low-Tax Developments (SHIELD).  Rather than imposing a minimum tax on a base that is adjusted to add back in certain deductions, the SHIELD would disallow deductions made to low-taxed members of a financial reporting group.  The Green Book proposal would also disallow net interest expense for tax purposes in excess of net interest expense reported on the financial statements.

The Green Book would also impose a 15 percent minimum tax on book earnings of large corporations and provide a tax credit to incentivize locating jobs and business activity in the United States.

Key topics covered in this online CPE/CE webinar:

  • Possible revision of GILTI to increase taxes directly by repealing the deduction for corporate U.S. shareholders and repeal the high tax exemption for GILTI and the rest of Subpart F (CFC rules).
  • Possible revision to GILTI to include more income abroad by eliminating the reduction for QBAI.
  • Possible revision to GILTI to foreclose planning opportunities by requiring jurisdiction-by-jurisdiction testing.
  • Planning to address these and other possible future changes to GILTI, including any similar changes that might occur in U.S. tax law or the tax law of U.S. trading partners as a result of the G7 Communique.
  • Possible revision of Section 7874 to classify more transactions as inversions and thus subject to that Section.
  • The replacement of BEAT with SHIELD to disallow deductions for all payments to low-taxed group members.

Click here for more IRS approved CE/CPE webinars on | Tax Updates | IRS Audit, Representation and Resolutions |

Learning Objectives

Upon successful completion of this course, participants will be able:

  • To discuss the implications of a revised GILTI and planning opportunities to maximize corporate efficiency.
  • To discuss how to plan for changes in Section 7874 when advising on possible cross-border mergers and acquisitions.
  • To discuss how developments at the upcoming G20 Meeting and at the OECD may guide U.S. tax law changes and may guide changes in other countries, all of these changes will impact taxpayers conducting international businesses.
  • To discuss how SHIELD will differ from BEAT and how to plan in anticipation of the adoption of SHIELD.

Who Should Attend?

  • Bookkeepers & Accountants & Tax Preparers
  • California Registered Tax Professional
  • Certified Public Accountant
  • CPA (Industry)
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • Enrolled Agent
  • Maryland Tax Preparers
  • Oregon Tax Preparers
  • Tax Accountant (Industry)
  • Tax Attorney
  • Tax Director (Industry)
  • Tax Firm
  • Tax Managers
  • Tax Practitioners
  • Tax Preparer
  • Tax Professionals
  • Tax Pros
  • Young CPA