Topics Covered
The webinar will explain the proposals in the BBBA to revise US tax provisions related to:
- the US GILTI regime for Global Intangible Low-Taxed Income, as it corresponds to the Income Inclusion Rule (IIR) of OECD Pillar Two
- the Base Erosion and Anti-Abuse Tax (BEAT), as it corresponds to the Undertaxed Payment Rule (UTPR) of OECD Pillar Two
- the US foreign tax credit limitation
The webinar will also address other notable proposals in the BBBA for: (i) a corporate alternative minimum tax based on income reported for financial purposes; (ii) the taxation of foreign-derived intangible income (FDII); (iii) limitations on deductions of interest; (iv) the taxation of foreign-source dividends; and (v) the withholding exemption for portfolio interest.
Learning objectives
After following this webinar, participants will be able to:
- identify the key components of the US GILTI regime as compared to the IIR of OECD Pillar Two
- apply the US foreign tax credit provisions to US controlled foreign corporations
- identify the key components of the US BEAT regime as compared to the UTPR of Pillar Two
- apply the US provisions for the corporate minimum tax, FDII, limitations on interest deductions, foreign-source dividends and portfolio interest
Instructors
Michael Lebovitz
John Rienstra
Field of study
Taxes
Who should participate?
The webinar is suitable for all tax professionals, including accountants, in-house tax personnel (e.g.
directors or managers), lawyers, advisers, policymakers and government officials who deal with cross-border transactions, structures or cases and wish to understand the key provisions of US tax law related to the Pillar Two framework and the key proposals being considered for US inbound and outbound investments.
Course level and prerequisites
This is an intermediate-level webinar. Participants in this webinar are expected to be familiar with the key concepts of Pillar Two, the related US GILTI and BEAT provisions and the basic provisions of the US international tax system.
Advance preparation
Participation in this webinar does not require any preparation.
Interactive webinar – “Group Internet Based” (live webinar only)
During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions or to complete short tests. Participants, who follow the live broadcast, will also have access to the on-demand version for a further 12 months from the live date.
Date of live broadcast: 10 February 2022.
On-demand webinar
On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months from the date of registration and/or live broadcast.
Continuing Professional Education
Many accrediting organizations will grant CPE credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well.
The International Bureau of Fiscal Documentation (IBFD) 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 the 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. Participants that follow the live webinar can claim 1 CPE credit while those following the on-demand version cannot claim the credits.
Webinar registration details
If you have any questions about following the webinar, technical requirements, or payments and cancellations, please consult our FAQ.