Regulatory Update – FTC/GILTI/FDII – Technical Issues and Modeling Considerations


Susan L. Curley, Ingram Industries, Vice Chair, TEI’s U.S. International Tax Committee


  • Michael J. Caballero, Covington & Burling LLP
  • Mark Gasbarra, Forte International Tax LLC
  • Adam S. Halpern, Fenwick & West LLP

The TCJA and subsequent administrative guidance continues to result in unexpected and sometimes surprising outcomes for multinational taxpayers’ tax planning and modeling, reaching in some cases counterintuitive results and upsetting old “rules of thumb.” This session will provide an update on the latest in regulatory and other guidance with respect to the worldwide allocation of interest expense, foreign tax credit, sourcing rules, new capitalization rules, and show the complex modeling necessary to produce predictable results under the TCJA’s GILTI and FDII regimes.

Learning Objectives: After this session, participants will be able to: (1) understand recent U.S. international tax regulatory changes; (2) assess the impact of such changes on their employers’ business operations; and (3) describe the factors that should be accounted for when modeling tax outcomes under the TCJA.

Location: Date: March 24, 2021 Time: 3:45 pm - 5:00 pm