Back to Basics: An International Tax Boot Camp in the Era of BEAT, GILTI, & FDII

Moderator:

Kent Cain, The Michaels Companies, Chair, TEI’s U.S. International Tax Committee

Speakers:

• Nicholas J. DeNovio, Latham & Watkins LLP
• Rocco V. Femia, Miller & Chevalier Chartered
• Sam K. Kaywood, Jr., Alston & Bird LLP

Session Description:

The Tax Cuts and Jobs Act (TCJA) of 2017 enacted the most significant changes to the U.S. international tax regime in more than a generation. New acronyms such as BEAT, GILTI, and FDII were introduced reflecting changes made by the TCJA. This session will begin with an overview of the BEAT, GILTI, and FDII regimes. The remainder of the session will be dedicated to discussing illustrative scenarios of the application of these regimes and how current transactional planning may differ from pre-TCJA planning.

Learning Objectives:

After this session, participants will be able to: (1) understand the basics of the BEAT, GILTI, and FDII regimes; (2) understand the primary impacts of such regimes on their employers’ business; and (3) assess the impact of such regimes on certain transactional structures.