2025 Tax Reform for Non-U.S. Investors and Companies: International Tax Provisions in the One Big Beautiful Bill Act
Key Issues Stemming From the New Tax Bill, Section 899, FDII, GILTI, BEAT, and More
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax counsel and advisers with a review of the application and impact of the new tax bill on international taxation and planning. The panel will discuss new tax law changes impacting international transactions and multinational business operations, including foreign-derived intangible income (FDII), global intangible low-taxed income (GILTI), base erosion and anti-abuse tax (BEAT), and other key provisions, and provide tax planning considerations to optimize tax benefits and avoid tax pitfalls.
Outline
- Overview of the OBBB
- Expansion of TCJA provisions
- Section 250 deductions for FDII and GILTI
- BEAT
- Section 174 and Section 163(j)
- New Section 899
- Unfair foreign taxes
- Tax rate increases
- Modifications to BEAT
- Planning considerations and best practices for tax counsel
Benefits
The panel will discuss these and other key issues:
- How does the OBBB modify international tax law provisions?
- What provisions of the TCJA does the OBBB seek to modify or expand?
- How do the new provisions impact taxpayers with multinational transactions and operations?
- What are the next steps and planning considerations for tax counsel and advisers?
Faculty
Seevun Dunckzar
Senior Manager
KPMG
Ms. Dunckzar provides strategic advice to national clients from a wide variety of industries, including... | Read More
Ms. Dunckzar provides strategic advice to national clients from a wide variety of industries, including technology and life sciences, on inbound and outbound U.S. international tax issues. She has helped clients work through the treatment and classification of controlled foreign corporations and passive foreign investment companies, as well as transfer pricing issues and the consequences of cross-border transfers of intellectual property, among other matters. Following the 2017 U.S. tax reform, Ms. Dunckzar has also helped clients implement and understand the new tax law, including the Base Erosion AntiAbuse Tax, and the Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income regimes.
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