To apprise accountants and tax professionals involved in international business of the expected changes to international taxation being proposed by the Biden Administration, Congress and foreign jurisdictions.

Presenters:

Jamal Aquil, Tax Associate, International, KPMG
Kevin Cunningham, Managing Director, KPMG

• Overview of Possible Tax Reform Outcomes
  – US and global (BEPS 2.0)
  – Planning framework
     – GILTI
     – FDII
• Planning Themes
  – Prepayment (goods, services, royalties)
  – FTC management
  – Loss, inbound and VCM planning
• Treasury “Green Book” Details for FY 2023
  – International proposals
     – Replacement of BEAT with Undertaxed Profits Rule
     – Expanded retroactive QEF election
     – Redefining Foreign Business Entity for Reporting Purposes
• Section 958 Final Regulations
  – PFIC and CFC proposals
  – Domestic partnerships
• Proposed Regulations
  – PFIC general background
  – Proposed aggregate treatment for QEF and MTM, and CFC Overlap Rule
• Final FTC Regulations
  – Tightening the scope of creditable tax
  – Attribution requirement (FKA jurisdictional nexus)
     – Affected taxes
     – Rules for nonresidents vs. residents

To apprise accountants and tax professionals involved in international business of the expected changes to international taxation being proposed by the Biden Administration, Congress and foreign jurisdictions.

Presenters:

Jamal Aquil, Tax Associate, International, KPMG
Kevin Cunningham, Managing Director, KPMG

• Understand the proposed corporate tax rate changes by different political parties

• Identify specific budget proposals affecting the IRS and tax filing programs

• Learn about the IRS's enforcement strategies and planned resource increases

• Recognize key legal doctrines influencing IRS and Treasury regulatory practices

• Understand the objectives of Pillar I in the OECD’s international tax framework

• Identify the threshold criteria for businesses subject to the global minimum tax under Pillar II

• Explore the CJEU's stance on state aid and multinational tax practices within the EU

• Recognize different countries’ approaches to implementing Pillar II and federal corporate taxes

• Understand the compliance implications for multinational enterprises under Pillar II

• Identify how statute of limitations applies to Treasury regulations following recent court rulings

• Overview of Possible Tax Reform Outcomes
  – US and global (BEPS 2.0)
  – Planning framework
     – GILTI
     – FDII
• Planning Themes
  – Prepayment (goods, services, royalties)
  – FTC management
  – Loss, inbound and VCM planning
• Treasury “Green Book” Details for FY 2023
  – International proposals
     – Replacement of BEAT with Undertaxed Profits Rule
     – Expanded retroactive QEF election
     – Redefining Foreign Business Entity for Reporting Purposes
• Section 958 Final Regulations
  – PFIC and CFC proposals
  – Domestic partnerships
• Proposed Regulations
  – PFIC general background
  – Proposed aggregate treatment for QEF and MTM, and CFC Overlap Rule
• Final FTC Regulations
  – Tightening the scope of creditable tax
  – Attribution requirement (FKA jurisdictional nexus)
     – Affected taxes
     – Rules for nonresidents vs. residents