transcript   Transcript

The International Tax Reform Provisions—Part 2

Recorded on: Feb. 5, 2018
Running Time: 01:12:56

Full Transcript:



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To access the streaming media of this presentation, please purchase the corresponding seminar segment.

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam.

Upon the successful completion of this program, the participant will be able to:

  • Recall the operation of the base erosion and anti-abuse tax (BEAT) provisions imposed pursuant to Internal Revenue Code (IRC) §59A.
  • Identify some of the questions surrounding the implementation of the base erosion and anti-abuse tax (BEAT) provisions of Internal Revenue Code (IRC) §59A.
  • Recognize the denial of deductions for certain payments to related hybrid entities and for hybrid transactions pursuant to Internal Revenue Code (IRC) §267A.  

Course Overview:

This program will focus on:

  • The operation of the base erosion and anti-abuse tax (BEAT) provisions imposed pursuant to Internal Revenue Code (IRC) §59A.
    • Calculation of BEAT.                                       
  • The questions surrounding the implementation of the base erosion and anti-abuse tax (BEAT) provisions of Internal Revenue Code (IRC) §59A.
    • Applicability of BEAT.     
  • The denial of deductions for certain payments to related hybrid entities and for hybrid transactions pursuant to Internal Revenue Code (IRC) §267A.
    • Hybrid entities.
    • Hybrid transactions.

CPE Program Level:  Overview

Intended Audience: CPA’s, tax accountants, tax lawyers, taxpayers, and others seeking the latest information on the implications of the Tax Cuts and Jobs Act (TCJA) with respect to the base erosion and anti-abuse tax (BEAT) provisions of IRC §59A, and the denial of deductions for certain payments to related hybrid entities and for hybrid transactions pursuant to IRC §267A.

Prerequisites:  A general background in the base erosion and anti-abuse tax (BEAT) provisions, and the denial of deductions for certain payments to related hybrid entities and for hybrid transactions pursuant to the latest provisions of the Internal Revenue Code (IRC).

Advanced Preparation: None

Instructional Method: QAS Self-Study

Updated: April 2018

Credit Information: 1 CPE credit is available upon completion of this program’s 3 content-review questions and a minimum passing score of 70% on the 5-question final exam. 


Taken from the Web Program The Tax Cuts and Jobs Act: Navigating the New Landscape Recorded February 2018 in New York

The International Tax Reform Provisions—Part 2 [01:12:56]

  • Tax on base erosion payments
  • Denial of deduction for certain payments to related hybrid entities and for “hybrid dividends”
  • Changes to the Subpart F income rules
  • Changes to the rules governing foreign tax credits

Jennifer S. Acuña, Manal S. Corwin, L. G. "Chip" Harter, Daniel M. McCall, Jose E. Murillo

Presentation Material

  • EY Global Tax Alert: US House and Senate release the Conference Report on the Tax Cuts and Jobs Act (December 21, 2017) - Handout
    Jose E. Murillo
  • Selected International Tax Provisions
    Manal S. Corwin, Jose E. Murillo
  • Selected International Tax Provisions P.L. 115-97
    Manal S. Corwin
(s)
Jennifer S. Acuña ~ Senior Tax Counsel and Policy Advisor, U.S. Senate Finance Committee
Manal S. Corwin ~ KPMG LLP
L. G. Chip Harter ~ Deputy Assistant Secretary (International Tax Affairs), U.S. Department of the Treasury
Daniel M. McCall ~ Deputy Associate Chief Counsel (International-Technical), Internal Revenue Service
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