Advanced Corporate Tax Planning & Emerging Issues Webinar

To provide tax professionals with an update on advanced tax planning developments, regulatory changes, and emerging compliance considerations impacting foreign investment structures, tax credits, sovereign wealth funds, and multinational entities.

• Developments under Section 892 and practical considerations for sovereign wealth funds and investment structures
• Proposed and final regulations involving effective control, debt investments, and commercial activity rules
• Foreign entity of concern (FEOC), specified foreign entity (SFE), and foreign-influenced entity (FIE) rules and related tax credit implications
• Material assistance rules, supply chain considerations, and practical impacts on energy and credit transactions
• Changes to downward attribution rules, Section 951B, and controlled foreign corporation planning considerations
• Practical implications of evolving IRS staffing, funding, enforcement, and regulatory developments
• Proposed Section 899 developments, Pillar Two considerations, and cross-border tax policy uncertainty

• Best practices for coordinating tax planning, fixed asset management, and financial reporting considerations

Jen Sabin, Partner, Gibson Dunn

To provide tax professionals with an update on advanced tax planning developments, regulatory changes, and emerging compliance considerations impacting foreign investment structures, tax credits, sovereign wealth funds, and multinational entities.

DETAILED LEARNING OBJECTIVES

• Identify key developments affecting foreign government investors under Section 892

• Recognize how effective control and debt investment rules may impact Section 892 eligibility

• Evaluate the practical implications of the final Section 892 commercial activity regulations

• Distinguish between Specified Foreign Entities (SFEs) and Foreign-Influenced Entities (FIEs)

• Identify the impact of FEOC provisions on energy and manufacturing tax credit eligibility

• Recognize the purpose and operation of the material assistance rules

• Understand the restoration of the prohibition on downward attribution under OBBBA and the creation of Section 951B

• Assess emerging international tax planning considerations resulting from IRS administrative changes and recent legislation

• Developments under Section 892 and practical considerations for sovereign wealth funds and investment structures
• Proposed and final regulations involving effective control, debt investments, and commercial activity rules
• Foreign entity of concern (FEOC), specified foreign entity (SFE), and foreign-influenced entity (FIE) rules and related tax credit implications
• Material assistance rules, supply chain considerations, and practical impacts on energy and credit transactions
• Changes to downward attribution rules, Section 951B, and controlled foreign corporation planning considerations
• Practical implications of evolving IRS staffing, funding, enforcement, and regulatory developments
• Proposed Section 899 developments, Pillar Two considerations, and cross-border tax policy uncertainty

• Best practices for coordinating tax planning, fixed asset management, and financial reporting considerations

Jen Sabin, Partner, Gibson Dunn