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TaxFirst webcast series

Be the first to know the impact of the new tax provisions

Deloitte’s TaxFirst webcast series is your go-to source for timely updates on regulatory guidance and tax law changes. Whether it is 163(j), Foreign Tax Credit, or Base Erosion and Anti-Abuse Tax (BEAT), Deloitte’s TaxFirst webcast series will provide you with information you need just days after new regulations are released.

About the series

The impact of the 2017 tax legislation continues with the release of each proposed regulation. How will you stay informed on the issues and new tax guidance coming out of Washington? Deloitte’s TaxFirst webcast series will provide insights and updates on regulatory guidance within days of release.

Be sure you receive invitations to TaxFirst webcasts by marking "tax" as an area of interest in your Deloitte.com profile.

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IRC Section 382 proposed regs: What tax execs need to know

Host: Jonathan Forrest
Presenters: Steve Harrison, Matthew Boyle

On September 9, 2019, the Treasury and IRS issued proposed regulations (REG-125710-18) on the items of income and deduction that are treated as built-in gains and losses under section 382. These proposed regulations are proposed to be effective for ownership changes occurring after the proposed regulations are finalized. What are important new developments tax executives should know about? We’ll discuss:

  • Key proposed changes to existing guidance under section 382.
  • Potential considerations for M&A transactions.
  • Changes to the calculations of net unrealized built-in gains and losses (NUBIG/NUBIL) under the proposed regulations.
  • Changes to the calculations of recognized built-in gains and losses (RBIGs/RBILs) under the proposed regulations.
  • Additional considerations for highly-leveraged companies.

Participants will gain high-level insights into the proposed regulations.

New section 451 regulations: Much needed clarification

Host: Bob Kilinskis
Presenters: Jane Rorhs, Neville Jiang

The long-anticipated proposed sections 451(b) and 451(c) regulations have been released, providing needed guidance in tax accounting for revenue recognition and advance payments. Do they address the many unanswered questions that existed based on the legislative history and the Joint Committee on Taxation Blue Book Explanation for sections 451(b) and 451(c)? We'll discuss:

  • Treasury's view on how the realization principle applies in concert with section 451(b).
  • How the regulations apply to both goods and services and severable vs. non-severable contracts.
  • How the regulations interact with other revenue recognition changes as a result of ASC 606, and potential new tax deferral considerations available under the guidance.
  • How the tax deferral method available under section 451(c) compares with Rev. Proc. 2004-34.

Participants will explore potential tax opportunities in implementing sections 451(b), 451(c), and ASC 606.

IRS issues final GILTI regulations: What’s next?

Host: Clifton Davis
Presenters: Ari Berk, Morgan Hann, Gretchen Sierra, Chris Trump, Jason Gritton

On June 21, 2019, the Treasury Department and Internal Revenue Service released final regulations on Global Intangible Low-Taxed Income (GILTI) provisions of the 2017 tax law. What has changed? What remains the same? What impact will this have on your future tax planning (and prior transactions)? Please join our panel of specialists, who will discuss:

  • The final Section 951A regulations, including rules associated with controlled foreign corporation (CFC) inclusion year, excess qualified business asset investment (QBAI), computation of tested income and losses, and determination of QBAI.
  • Insights on the expanded elective GILTI high tax exclusion that applies to certain high-taxed income, including making the election, calculation of high taxed income, and impact on attributes.
  • Certain Foreign Tax Credit Regulations that were finalized as part of the same package and may impact your prior year treatment of certain transactions.
     

Qualified Opportunity Zones: A guide to the latest regulations

Host: Marty Karamon
Presenters: Gary Hecimovich and Jeremy DeMuth

Qualified Opportunity Zones (QOZs) are a new economic development tool enacted as part of the 2017 tax legislation, designed to spur investment in distressed communities. What should tax executives know about recently proposed regulations around QOZs? We’ll discuss:

  • A brief overview of QOZs and the Qualified Opportunity Fund, the mechanism for making QOZ investments
  • Three types of potential QOZ benefits and practical examples of how they might apply
  • Key QOZ considerations, including structuring concepts, qualified investments; important dates, compliance issues, and associated penalties
  • Insights on proposed QOZ regulations issued by the Treasury Department and the IRS


 

Proposed section 250 regulations: Decision time?

Host: Derek Schraw
Presenters: Jason Gritton, Jenny Voorhees, Bob Stack

On March 6, 2019, the Treasury Department and Internal Revenue Service released proposed regulations on the foreign-derived intangible income (FDII) deduction. What are the important new developments tax executives should know about? We’ll discuss:

  • Key provisions of the proposed regulations and how they might impact the calculation of a company’s FDII
  • What a company should consider to address its FDII reporting requirements, including identifying specific required data points, sourcing the data, and effectively using analytics
  • Other planning considerations, including calculation of Deduction Eligible Income (DEI), Foreign-derived Deduction Eligible Income (FDDEI), and Qualified Business Asset Investment (QBAI)

Participants will learn about the proposed regulations and explore ways to analyze and document the potential impacts of the new deduction.

IRC Section 965 final regs: What tax execs need to know

Host: Brandon Bingham
Presenters: Paul March, Doug Giles, Rosemary Sereti, Scott Schiefelbein, and Ashley Martinez

On January 15, the Treasury Department and Internal Revenue Service released final regulations on the transition tax under section 965. What are important new developments tax executives should know about? We’ll discuss:

  • Key changes from the proposed section 965 rules that the IRS released in August 2018 and how they might impact the calculation of a company’s transition tax.
  • Potential impacts of making elections and various issues implicated by internal transactions.
  • Tax compliance implications of the final regulations.
  • Considerations for your state tax returns, including state tax compliance issues.

Participants will gain high-level insights into the final regulations and practical considerations for compliance with the new rules.

New guidance under section 199A

Host: Wolfe Tone
Presenters: Edward Gershman, Laura Howell-Smith, Grace Melton, and Jane Rohrs

On January 18, 2019, the Treasury Department and the IRS released new guidance, including final regulations under section 199A regarding the deduction for qualified business income (QBI) from partnerships, S corporations, and sole proprietorships. What do taxpayers need to know? We’ll discuss:

  • An overview of the final regulations, including a number of clarifying changes and new aggregation rules for relevant passthrough entities, and new proposed regulations released January 18, 2019; 
  • The new trade or business safe harbor rules for rental real estate enterprises;
  • Methods for calculating W-2 wages for purposes of section 199A.

IRC Section 267A: Regulatory response to hybrid mismatch transactions

For years, many multinational companies have used hybrid entities and hybrid instruments in intragroup transactions. How does the new section 267A proposed regulations impact such entities and transactions? We’ll discuss:

  • The analytical framework for hybrid mismatches adopted from the OECD BEPS project.
  • Entities and transactions subject to the proposed section 267A regulations, including hybrid transactions, disregarded payments, branch mismatch payments, and imported mismatches.
  • The interaction between section 267A, subpart F, and global intangible low-taxed income (GILTI) tax rules.
  • Future directions for intercompany financing.

New proposed Section 59A regulations: What you need to know about the BEAT

The US Department of the Treasury and IRS have released guidance for section 59A of the 2017 US tax law. What should tax executives of multinational businesses know about the base erosion and anti-abuse tax (BEAT)? We’ll discuss:

  • An overview of the new guidance
  • Key issues to be aware of for BEAT calculations 
  • Practical planning considerations for the 2018 tax season

New guidance on foreign tax credit (FTC) and business expenses: What you should know

On November 28, the US Department of the Treasury and IRS released new guidance addressing changes to the foreign tax credit rules in the 2017 tax law. In addition to providing guidance on the allocation and apportionment of expenses among and between the new categories of income, including Global Intangible Low-Tax Income (GILTI) and branch income, the tax community hopes the new regulations provide clarifications about how taxpayers compute their residual tax on the GILTI inclusion. Does updated guidance answer these questions? We’ll discuss:

  • An overview of the new guidance
  • Impact on companies’ residual US federal income tax on GILTI inclusions
  • Practical considerations to be aware of in assessing US federal tax position

New Section 163(j) proposed regulations: What are your options?

On November 26, the US Department of the Treasury and IRS released new proposed regulations under Section 163(j) of the 2017 Tax Act. How could this interest deduction limitation increase your tax liability and change how your company raises capital and invests in future growth? Join our webcast as we discuss:

  • An overview of the new proposed regulations
  • Alternatives to preserve the interest deduction
  • The new compliance and reporting requirements under Section 163(j)

Midterm elections and the tax landscape: What now?

The midterm elections are over and the political die is cast for the next two years—or is it? What can businesses expect going into 2019 in terms of tax policy, regulations, and enforcement activities? We’ll discuss:

  • A recap of election results and key tax considerations for year-end 2018, including observations on the impact of the 2017 tax bill and trade policies. 
  • What to expect in 2019, including the likelihood of changes in tax legislation, new regulations, and potential areas of compromise between Congress and the White House.

View the webcast on-demand to gain new insights on the results of the 2018 midterm elections and their possible impacts across the tax environment.

Today’s tax reform ambiguity will eventually become your new tax reality. What you do now—the planning, decisions, and actions you take—can put your company in the best possible position to cope with the new tax laws. Deloitte Tax LLP can help you face your new tax reality with confidence.

For additional webcasts from Deloitte, check out Tax Executives Dbriefs and Tax Reform Dbriefs.

 

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