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Deep Dive into GILTI and New Global Minimum Tax Developments

The International Tax Regime: Nothing to feel GILTI About

  • Price

    $29

  • Total Credits

    2 CPE

Deep Dive into GILTI and New Global Minimum Tax Developments

Overview

The 2017 Tax Act introduced a lot of changes to the Internal Revenue Code, but arguably none bigger or more important than the introduction of Global Intangible Low Tax Income (“GILTI”), which has turned completely up-side-down the US taxation of offshore business activities conducted through controlled foreign corporations (“CFCs”).

GILTI – notwithstanding its name -- is actually NOT a tax on “intangible income” in low tax jurisdictions, but rather a US income tax imposed on all income of a CFC, minus a (relatively paltry) allowable amount, where the CFC income has not been taxed by the home jurisdiction at a tax rate of at least 13.125%. In such cases, the US basically steps in and takes the position that, “Heck, if no one else is going to tax that income, we will!”

The world is constantly moving towards new tax regimes recently in July 2021, some 130 nations have agreed to what would be the biggest international tax reform in a generation to clamp down on big companies that are gaming the rules.

The G20 nations are now expected to endorse a provisional deal reached under the auspices of the OECD, adding momentum to reach a final deal by October and convince hold-outs to join.

This virtual CPE conference will provide a deep dive regarding the GILTI regime and proposed global minimum tax regime and the speaker Jonathan Grossberg will also discuss various ideas and strategies on how best to manage the curious and quirky provisions.

Canceled

Continuing Education Credits

The sessions of the conference qualifies for

  • 2 CE Credit for all AFSP
  • 2 CPE Credit for all CMA
  • 2 CPE Credit of Taxes for CPA (US)
  • 2 CE Credit of Federal Tax Related Matters for EA
  • 2 CE Credit for all Oregon Tax Preparer
  • 2 CE Credit for all CTEC
  • 2 CE Credit for all Maryland Tax Preparer

Speakers

Jonathan Grossberg

Jonathan Grossberg

Owner , Grossberg Continuing Education

Jonathan D. Grossberg, J.D., LL.M. (Taxation) is a licensed attorney in Pennsylvania and New York.  He is Assistant Editor, National Income Tax Workbook published by the Land Grant University Tax Education Foundation, Inc., and Adjunct Professor of Law, Temple University Beasley School of Law.  Until August 2020, he was Assistant Professor of Taxation at Robert Morris University (RMU) School of Business in Moon Township, PA.  Jonathan has taught a wide variety of tax courses to undergraduate, graduate, and law students, including federal income taxation, taxation of business entities, tax procedure, advanced income taxation, tax research, corporate tax, and international tax.  Before entering academia, Jonathan clerked for Judge Gale of the U.S. Tax Court and practiced tax law at Drinker Biddle & Reath LLP in Philadelphia and Milbank, Tweed, Hadley & McCloy LLP in New York.  Jonathan has written articles for academic and practitioner publications and made CLE/CPE presentations to lawyers and accountants on a variety of topics including tax and business ethics, judicial doctrines in tax law, partnership tax, tax issues facing small businesses, and universal basic income.

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Session Details

Jonathan Grossberg
Jonathan Grossberg

Date

Oct 5th, 2021

Time

12:00 PM – 01:00 PM
1 Credits

Step-by-step process for converting your balance sheet

The GILTI structure was designed with intangible, low tax income in mind, as the name implies, but it actually affects companies in a variety of ways. If a company has all its foreign earnings in a jurisdiction that does not have a corporate tax, then GILTI acts as a minimum tax on those profits, generally at an effective rate near 10.5 percent, which is half the current U.S. corporate rate.
However, this is not a typical situation. Many companies have their foreign operations near their customers in jurisdictions where they would owe at least some amount of corporate tax on their foreign earnings.
In principle, GILTI is attempting to balance both base erosion and competitiveness concerns. However, it doesn’t seem like the law operates precisely as Congress intended.
One area which has garnered significant attention recently is GILTI’s treatment of companies with high-taxed foreign profits. Under current law, foreign tax credits face a limitation. The limitation is that the credit is based on a formula, which cannot exceed your U.S. tax liability multiplied by the share of foreign profits divided by your worldwide profits. The purpose of this limitation is to prevent companies from using foreign tax credit to offset domestic taxes.

Major topics covered in this online CPE session:

  • Structure and Purpose of GILTI
  • Does GILTI really work as intended?
  • What’s next?

Learning Objectives

  • To determine what in principle GILTI is attempting to balance
  • To describe the rules that are part of the foreign tax credit limitations
  • To discuss the proposed changes IN GILTI
  • 1 CE credit of for all AFSP
  • 1 CPE credit of for all CMA
  • 1 CPE credit of Taxes for all CPA (US)
  • 1 CE credit of Federal Tax Related Matters for all EA ( Course No. GEHNZ-T-00636-21-O )
  • 1 CE credit of for all Oregon Tax Preparer ( Course No. GEHNZ-T-00636-21-O )
  • 1 CE credit of for all CTEC ( Course No. 6273-CE-0603 )
  • 1 CE credit of for all Maryland Tax Preparer ( Course No. GEHNZ-T-00636-21-O )

Subject Area:

Taxes,Federal Tax Related Matters

Course Level:

Intermediate

Instuctional Method:

Group Internet Based

Pre-requisites:

Advance Preparation:

Jonathan Grossberg
Jonathan Grossberg

Date

Oct 5th, 2021

Time

01:00 PM – 02:00 PM
1 Credits

A New Global Minimum Tax Regime?

In July 2021, world leaders reached a deal to make multinational companies pay more tax, after several years of negotiation. They agreed to introduce an overall global minimum corporate tax rate of at least 15% with the aim of preventing tax competition. The political agreement was reached among the 130 of the 139 countries involved in the OECD/G20 Inclusive Framework, after the G7 gave the deal momentum in June.  Countries of the G20 further backed the agreement during the following meeting of their finance ministers.
If adopted, a global minimum tax will apply to all sectors of the economy. Countries will have to repeal tax incentives in domestic law and investment agreements in order to bring the effective tax rate in line with the global tax rate
The proposed reform is comprised of two pillars to prevent companies from establishing bases in countries with low taxes to maximise profits earned elsewhere. 130 countries and jurisdictions have joined a new two-pillar plan to reform international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate.

Major topics covered int this online CPE session:

  • What is the purpose behind bringing in new global concept?
  • Is the framework finalised?
  • What are the two pillars of the reform?

Learning Objectives

  • To discuss the effects of global minimum tax regime on the economy
  • To discuss the impact on tax incentives
  • To discuss the two pillars of the new reform
  • To discuss how countries will be affected by the new reform
  • 1 CE credit of for all AFSP
  • 1 CPE credit of for all CMA
  • 1 CPE credit of Taxes for all CPA (US)
  • 1 CE credit of Federal Tax Related Matters for all EA ( Course No. GEHNZ-T-00637-21-O )
  • 1 CE credit of for all Oregon Tax Preparer ( Course No. GEHNZ-T-00637-21-O )
  • 1 CE credit of for all CTEC ( Course No. 6273-CE-0604 )
  • 1 CE credit of for all Maryland Tax Preparer ( Course No. GEHNZ-T-00637-21-O )

Subject Area:

Taxes,Federal Tax Related Matters

Course Level:

Intermediate

Instuctional Method:

Group Internet Based

Pre-requisites:

Advance Preparation:

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