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The U.S. Contribution to BEPS: GILTI and BEAT 1 Credit 1 Credit

Sep 23, 2021, 12:00 PM ET

The U.S. Contribution to BEPS: GILTI and BEAT 1 Credit 1 Credit

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Sep 23, 2021, 12:00 PM ET

Learning Objectives

  • To discuss the Tax Planning Impacts of GILTI and BEAT.
  • To review the Relationships between TCJA's GILTI and BEAT provisions and the OECD's Unified Framework.
  • To describe the differences between international tax systems: world-wide, territorial and destination-based.
  • To evaluate the TCJA shift from a Global Tax to a Territorial One.
  • To recognize the importance of the TCJA Participation Exemption.
  • To identify how GILTI and FDII incentivize U.S. Businesses to keep I.P. related profits in the U.S. 
  • To describe the arc of the fifteen (15) BEPS articles.
  • To determine the relationship between TCJA and BEPS Pillar's One and Two.
  • To describe the new taxing right under Pillar One and its relationship to the destination-based tax framework. 
  • To determine how BEAT and Pillar Two merge toward a new Global Minimum Tax.
  • To describe how Pillar One dilutes the Arm's Length Standard and replaces it with Understand how Global Formulary Apportionment is becoming the basis for International Taxation.

Course Overview

This CE webinar's focus is the overhaul of the International Tax System, which has been ongoing since 2015, and the corresponding impact on current tax practice.  Without this knowledge, a tax practitioner will not understand the currently proposed critical policy changes in the International Tax arena.  

The topics discussed in this CPE/CE course are a sea change in thinking regarding the global economy's corporate taxation. The drivers of the sea change are the U.S. and the OECD. The CE course gives an overview and demonstration of the interrelationships between the U.S. developed GILTI and BEAT, and the OECD inspired Unified Framework of Pillar One and Two.

The rules changes driving today's evolving global tax ecosystem stem from:   

    • The Tax Cuts and Jobs Act of 2017 ("TCJA"), 
    • The finalization of the OECD's 2015 Base Erosion Profit Shifting ("BEPS") initiative.  


    A massive Global effort by OECD member countries, BEPS contains 15 Articles designed to deal with: 

    • Various "gaps" of the International Tax System
    • Businesses continued transition to online and digital platforms in Global International trade, rather than the more traditional "bricks and mortar" presence.

    The gap garnering the most attention is the last item, the taxation of the Digital Economy embedded within the OECD's Unified Framework of Pillar One and Pillar two. Pillar One and Two are similar in purpose to GILTI and BEAT

    The TCJA was the United States congressional revenue act that amended the Internal Revenue Code of 1986. Significant changes included reducing tax rates for businesses and individuals, reducing the alternative minimum tax (“AMT”) for individuals, and eliminating AMT for corporations. 

    The TCJA made substantial changes to the way U.S. multinationals' foreign profits are taxed. The significant elements of this change include the Global Intangible Low Tax Income ("GILTI") and The Base Erosion and Anti-Abuse Tax ("BEAT").  The GILTI is an outbound anti-base erosion provision. GILTI reduces the incentive to shift corporate profits out of the United States via base shifting a corporation's principal asset, intellectual property ("I.P.").  The BEAT penalizes base shifting via a focus on many types of outbound deductible payments by a U.S. Corporation that can erode the U.S. tax base. GILTI prevents base shifting of I.P., and BEAT acts as a minimum tax.  Taken together, FDII and GILTI work in tandem, discouraging U.S. Multinationals from shifting profits and intellectual property out of the United States and eroding the tax base.

      Major topics covered in this online CPE webinar:

      • The basics of TCJA: What are GILTI and BEAT? 
      • What are the newly-defined categories of foreign income to be added to corporate taxable income each year?  
      • What is Foreign Derived Intangible Income (“FDII”), and how does it relate to GILTI? 
      • What is the participation exemption? 
      • What is the OECD's Unified Framework?
      • What are "supernormal" returns, or returns above 10 percent of qualified investments? 
      • What are the "net tested income" and the "Qualified Business Asset Investment" aspects of GILTI 
      • What is the "one CFC" approach of GILTI 
      • What is the "modified taxable income" of BEAT? 
      • What are the Effective Dates of the Regulations? 
      • What are the future scheduled changes and associated impacts of GILTI and BEAT? 

      On Demand Credits for All Qualifications

      Live Webinar Credits for All Qualifications

      License details Credits Status
      Taxes for Certified Public Accountants (CPA-US) 1 CPE Approved
      Taxes for Enrolled Agents (EA) (Approval No. GEHNZ-T-00709-21-O) 1 CE Approved
      Taxes for Annual Filing Season Program (AFSP) 1 CE Approved
      Accounting & Auditing for Certified Internal Auditors (CIA) 1 CPE Eligible
      Federal Tax Related Matters for California Registered Tax Preparers (CRTP) (Approval No. 6273-CE-00664) 1 CE Approved
      Federal Tax Related Matters for Oregon Registered Tax Preparers (ORTP) (Approval No. GEHNZ-T-00709-21-O) 1 CE Approved
      Internal Audit Practitioner (IAP) 1 CPE Eligible
      Certified Wealth Strategist (CWS) 1 CE Eligible
      Certified Fiduciary and Investment Risk Specialist (CFIRS) 1 CE Eligible
      Qualification in Internal Audit Leadership (QIAL) 1 CPE Eligible
      Federal Tax Related Matters for Maryland Tax Preparer (MRTP) (Approval No. GEHNZ-T-00709-21-O) 1 CE Approved
      License details Credits Status
      Taxes for Certified Public Accountants (CPA-US) 1 CPE Approved
      Taxes for Enrolled Agents (EA) (Approval No. GEHNZ-T-00709-21-O) 1 CE Approved
      Taxes for Annual Filing Season Program (AFSP) 1 CE Approved
      Accounting & Auditing for Certified Internal Auditors (CIA) 1 CPE Eligible
      Federal Tax Related Matters for California Registered Tax Preparers (CRTP) (Approval No. 6273-CE-00664) 1 CE Approved
      Federal Tax Related Matters for Oregon Registered Tax Preparers (ORTP) (Approval No. GEHNZ-T-00709-21-O) 1 CE Approved
      Internal Audit Practitioner (IAP) 1 CPE Eligible
      Certified Wealth Strategist (CWS) 1 CE Eligible
      Certified Fiduciary and Investment Risk Specialist (CFIRS) 1 CE Eligible
      Qualification in Internal Audit Leadership (QIAL) 1 CPE Eligible
      Federal Tax Related Matters for Maryland Tax Preparer (MRTP) (Approval No. GEHNZ-T-00709-21-O) 1 CE Approved

      Additional Information

      Credit

      1

      Course Level

      Basic

      Instructional Method

      QAS Self Study

      Group Internet Based

      Pre-requisites

      None

      Advance Preparation

      None

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      About Instructor

      Attend informative CE/CPE webinars by William Seeger

      William Seeger

      President, QuantEcon Consulting

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      Dr. Seeger is currently a Clinical Professor of Economics at the University of Texas at Arlington, College of Business Administration, and President of Quantecon Consulting, an Economic consulting firm.  The focus of his academic research is Transfer Pricing and International Tax issues. Upon his retirement in October 2014, Dr. Seeger was a Principal in KPMG’s Global Transfer Pricing Services practice. He was practice leader, Economic and Valuation Services, for the Dallas, Houston and Denver Business Units and a senior economist and Southwest area lead for KPMG’s Economic Consulting Practice. Dr. Seeger has twenty years of experience in public accounting and three years’ experience with the Internal Revenue Service as an Industry Economist in the Comprehensive Examination Program. 

      In his public accounting career, Dr Seeger specialized in economic and tax issues related to tax efficient structuring of the operations of multinational organizations. He has advised clients on the Transfer Pricing economics related to intercompany financing, deferral, intangible planning, services, shared cost allocations, and operational price setting. While at KPMG, Dr. Seeger led Transfer Pricing teams as part of KPMG's financial statement audits of clients related to Fin 48 matters, assisted in Transfer Pricing Dispute Resolution, helped clients with negotiating and establishing their Advance Pricing Agreements, worked with KPMG's Mergers and Acquisitions teams on Transfer Pricing exposures of potential target acquisitions, and served as part of KPMG's Quality review team finalizing TP reports for release to clients.

      As the market leader for KPMG in the Dallas/Denver Business unit, Dr. Seeger had oversight in the areas of Oil and Gas, Engineering and Construction, Consumer and Industrial Business, and Financial Services. He was the Southwest area practice leader for Transfer Pricing services and Economic Consulting Services, the Global market leader for Energy and Natural Resources in the areas of oil and gas, chemicals, utilities, engineering and construction, and mining and forestry, and the National Transfer Pricing leader for the Engineering, Construction, and Procurement industry market segment.

      Dr. Seeger has a PhD and MA in Political Economy from the University of Texas at Dallas, with specializations in Industrial Regulation and Econometrics, and a BA in Economics from the University of Notre Dame, with a concentration in Quantitative Economics. He is currently a candidate for a Master’s degree in Jurisprudence in International Taxation from the Texas A&M University Law School.  

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      To earn CPE credits, you must complete the self-study course, pass the required assessments, and submit the necessary documentation. Credits are awarded based on the completion of course hours and successfully passing the assessments.

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      Yes, all our self-study courses are approved by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies, ensuring they meet the rigorous standards for quality and educational content set by these organizations.

      What are the requirements to maintain compliance with self-study courses?

      To maintain compliance, you must follow the guidelines set by NASBA and other regulatory bodies, which include completing the course within the specified timeframe, passing the assessments, and keeping accurate records of your learning activities.

      How can I access my course completion certificates?

      After successfully completing a self-study course and passing the assessments, you can access and download your course completion certificates from your account dashboard on our platform. These certificates are recognized by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies for compliance and reporting purposes.

      How are credits reported to governing bodies?

      We issue instant credit certificates, ensuring they are valid for presentation to governing bodies. Typically, we report IRS, CTEC, CFP, IDFP, IWI, VBOA Ethics credits within 7 days – the fastest in the industry.

      Live Webinar FAQs

      What is a Live Webinar Group Internet-Based Credit?

      A Live Webinar Group Internet-Based Credit is an interactive, real-time online seminar where professionals can earn Continuing Education credits by participating in live sessions led by experts in various fields. These sessions meet the standards set by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies.

      How do I earn credits through live webinars?

      To earn credits, you must attend the entire live webinar, actively participate in any polls or questions, and complete any required evaluations or assessments. Credits are awarded based on your attendance and participation in the live session.

      Are the live webinars approved by NASBA and other regulatory bodies?

      Yes, all our live webinars are approved by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies, ensuring they meet the high standards for quality, interactivity, and educational content set by these organizations.

      What are the requirements to maintain compliance with live webinar courses?

      To maintain compliance, you must adhere to the guidelines set by NASBA and other regulatory bodies, which include attending the full duration of the webinar, participating in interactive elements, and completing any post-webinar evaluations or assessments.

      How can I access my webinar completion certificates?

      After successfully attending a live webinar and fulfilling all participation requirements, you can access and download your completion certificates from your account dashboard on our platform. These certificates are recognized by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies for compliance and reporting purposes.

      How are credits reported to governing bodies?

      We issue instant credit certificates, ensuring they are valid for presentation to governing bodies. Typically, we report IRS, CTEC, CFP, IDFP, IWI, VBOA Ethics credits within 7 days – the fastest in the industry.

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