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

  • Accountant
  • AFSP
  • CRTP
  • CIA
  • CPA (US)
  • EA
  • IAP
  • ORTP
  • QIAL
  • MRTP
  • CFIRS
  • CWS

Published: November, 2021

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  • Course Description
  • Course Qualification
  • Presenter
  • FAQ

Course Description

Overview

  • Tax Reform's new regime for cross-border income
    3 mins
  • Global intangible low-taxed income (GILTI)
    10 mins
  • Base erosion and anti-abuse tax
    14 mins
  • How did the us get here?
    29 mins
  • Ownership of a controlled foreign corporation (CFC)
    40 mins

Course Description

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? 


Note:- William Seegar moved on from this world. With sadness in our hearts, we find solace in knowing that he’s in a better place. This is a recorded webinar of his live webinar. For any queries please contact us at support@my-cpe.com

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.

Recommended For

  • This IRS-Approved CE course is recommended for CPAs, EAs, AFSPs, Tax Directors, Tax Staff, Transfer Pricing Practitioners, Treasury, Internal Auditors, Tax Attorneys, CEOs and CFOs desiring to learn about BEPS, GILTI, and Beat.

Who Should Attend?

  • Annual Filing Season Program
  • California Registered Tax Professional
  • CPA (Industry)
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • CPA in Business
  • Enrolled Agent
  • Entrepreneurial CPA
  • Maryland Tax Preparers
  • Oregon Tax Preparers
  • Tax Director (Industry)
  • Tax Firm
  • Tax Managers
  • Tax Practitioners
  • Tax Preparer
  • Tax Professionals
  • Tax Pros
  • Young CPA

Course Qualification

Webinar Qualifies For

  • 1 CE Credit of Federal tax-related matters for Enrolled Agents (EA) (Approval No. GEHNZ-T-00709-21-S)
  • 1 CPE Credit for Certified Public Accountants (CPA-US)
  • 1 CE Credit for California Registered Tax Preparers (CRTP) (Approval No. 6273-CE-0664)
  • 1 CE Credit of Federal tax-related matters for Annual Filing Season Program (AFSP) (Approval No. GEHNZ-T-00709-21-S)
  • 1 CE Credit of Federal tax-related matters for Oregon Registered Tax Preparers (ORTP) (Approval No. GEHNZ-T-00709-21-S)
  • 1 CE Credit of Federal tax-related matters for Maryland Tax Preparer (MRTP) (Approval No. GEHNZ-T-00709-21-S)
  • 1 CE Credit for Certified Fiduciary & Investment Risk Specialist (CFIRS)
  • 1 CE Credit for Certified Wealth Strategist (CWS)
  • 1 General Credit for Accountant/Bookeeper

Additional details

  • Course Level :
    Basic
  • Credits :
    1
  • Instructional Method :
    QAS Self Study
  • Pre-requisites :
    None
  • Advance Preparation :
    None

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MY-CPE LLC (Sponsor Id#: 143597) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.NASBARegistry.org.

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MY-CPE LLC (Sponsor ID# : 6273) has been approved by the California Tax Education Council to offer continuing education courses that count as credit towards the annual “continuing education” requirement imposed by the State of California for CTEC Registered Tax Preparers. A listing of additional requirements to register as a tax preparer may be obtained by contacting CTEC at P.O. Box 2890, Sacramento, CA, 95812-2890, toll-free by phone at (877) 850-2832, or on the Internet at www.ctec.org.

Presenter

About Presenter

William Seeger

President, QuantEcon Consulting

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.  

About Company

QuantEcon Consulting

quanteconconsulting.com/

Economic Consulting Services including Transfer Pricing / Dispute Resolution / International Trade / Policy & Taxation / Forensic Investigation / Public Speaking for mid to large size businesses.

We are a team of diverse professionals who recognize that success in business depends upon a multidisciplinary approach to problems. Problems and their solutions are never one dimensional;  as such our diverse skills provide a unique platform upon which all facets of a challenging problem can be assessed and solutions discerned and derived. 

The first thing we'll do for you is listen. We need to understand your perspective and point of view on the challenges you face. Second, we become experts on your business model and your position in the marketplace. Thirdly, we provide value by providing the right solution that comports with your facts and unique circumstances. Finally, we don't fold up our consulting tent and walk away; instead we partner with you on the implementation of our proposed solution.

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