International Taxation Update - Post OBBBA Webinar

To update CPAs and other financial professionals on the latest developments in financial reporting from the FASB. You’ll learn how to apply all of the most recent pronouncements effectively and efficiently, and get an overview of the latest SASs and other current auditing issues.

• Sweeping changes to the IRS and US international tax regime following the inauguration of President Trump
• Effects of significant IRS downsizing, including impacts on regulatory guidance
• International tax provisions following the enactment of OBBBA
• Refresher on Pillar II, latest developments including the shift to a “side-by-side” solution, and predictions for future implementation

Matt Donnelly, Partner, Gibson, Dunn & Crutcher, Washington DC

Benjamin Fryer, Partner, Gibson, Dunn & Crutcher, London

Anne Devereaux, Of Counsel, Gibson, Dunn & Crutcher, Los Angeles

To update CPAs and other financial professionals on the latest developments in financial reporting from the FASB. You’ll learn how to apply all of the most recent pronouncements effectively and efficiently, and get an overview of the latest SASs and other current auditing issues.

DETAILED LEARNING OBJECTIVES

• Understand the major structural changes to the IRS introduced in 2025, including the elimination of key divisions and the impact on tax administration

• Recognize the extent of IRS leadership turnover in 2025 and its implications for regulatory consistency and enforcement

• Explain the effect of Executive Order 14192 on the federal regulatory process and its specific application to the IRS

• Identify how the One Big Beautiful Bill Act (OBBBA) modified the GILTI regime, including the transition to Net CFC Tested Income (NCTI) 

• Understand which international tax provisions were made permanent under OBBBA, specifically the CFC look-through rule

• Recall the new permanent BEAT rate established by OBBBA for tax years beginning after December 31, 2025

• Describe the purpose and scope of the OECD/G20 Pillar II initiative, including the 15% global minimum tax framework for large multinational enterprises

• Explain the substance of the “side-by-side” solution reached by the G7 and US Treasury in 2025 and its recognition of US NCTI/GILTI as compatible with Pillar II

• Sweeping changes to the IRS and US international tax regime following the inauguration of President Trump
• Effects of significant IRS downsizing, including impacts on regulatory guidance
• International tax provisions following the enactment of OBBBA
• Refresher on Pillar II, latest developments including the shift to a “side-by-side” solution, and predictions for future implementation

Matt Donnelly, Partner, Gibson, Dunn & Crutcher, Washington DC

Benjamin Fryer, Partner, Gibson, Dunn & Crutcher, London

Anne Devereaux, Of Counsel, Gibson, Dunn & Crutcher, Los Angeles