Tax News & Views webcast

Final foreign currency rules and what they could mean for your company

Date: December 20, 2024, 12:00 p.m. ET
Duration: 60 minutes
Host: Adam Moehring
Presenters: Matt Heeman, Michael Kohler, Michael Mou, Aziza Yuldasheva

1 Overview CPE credit | Taxes

Final regulations under section 987 address computing taxable income, translating tax basis, and recognizing currency gain or loss for qualified business units operating in different functional currencies. While the final rules largely follow the basic construct under the 2023 proposed regulations, there are notable differences. We’ll discuss:

• Simplifications introduced in the final regulations
  
• Transitioning to the final rules and coordinating with other tax rules
  
• Impact of the final rules on tax compliance and planning considerations
  

Participants will be able to describe the impact of the final section 987 regulations on US and foreign companies operating in foreign currency environments. 

Newly proposed PTEP regulations: unpacking the complexity

Date: December 13, 2024, at 11:00 a.m. ET
Duration: 60 minutes
Host: Adam Moehring
Presenters: Matt Etzl, Mark Graham, Jason Smyczek

1 Overview CPE credit | Taxes

On November 29, 2024, Treasury and the IRS released long-awaited guidance related to previously taxed earnings and profits (PTEP) accounting and associated basis adjustments to take into account the significant changes to the US international tax system implemented by the 2017 Tax Cuts and Jobs Act. What do multinational companies need to know about this regulatory package? We’ll discuss

• Framework for establishing, maintaining, and updating PTEP accounts
  
• Section 961 basis adjustments and gain recognition
• Transition rules and effective dates

Participants will be able to analyze the impact of the new PTEP regulations on US and foreign companies.

The post-election tax policy landscape

Date: Friday, November 8, 2024, 11:00 a.m. ET
Duration: 60 minutes
Host: Adam Moehring
Presenters: Anna Taylor,  Jon Traub

1 Overview CPE credit | Taxes

The elections are just days away. Once a new president and Congress prepare to govern, focus will turn to the fiscal cliff resulting from the expiration of major portions of the Tax Cuts and Jobs Act of 2017. Join us to hear what changes may be ahead in the coming debate on corporate, individual, and international tax policy. We’ll discuss:

• Potential tax policy changes under consideration
• Expectations for the legislative calendar and process in the new Congress
• How political dynamics may lead to surprising outcomes for individuals and businesses

Participants will be able to analyze the future tax policy landscape with a focus on key legislative issues.

Date subject to change and dependent upon timing of election results. Alternative date will be either November 13 or November 15 at 11 a.m. ET. If a date change is necessary, an email with details will be sent to registrants.

Corporate alternative minimum tax (CAMT) – latest guidance

Date: October 16, 2024, 11:00 a.m. ET
Duration: 60 minutes
Host: Adam Moehring
Presenters: John L. Franco, Wendy Friese, Alice Loo, Preston Pittman, Lauren Richards

1 Overview CPE credit | Taxes

On September 12, 2024, Treasury and the IRS released proposed regulations that provide guidance on the application of the corporate alternative minimum tax (CAMT) under sections 55, 56A, and 59(k) and (l). In this webcast, we’ll discuss:

• A refresher on CAMT including rules for determining applicable corporation status
  
• Reliance on the prior IRS Notices and the proposed regulations
  
• Applicability dates of the proposed regulations
  
• Highlights and key takeaways of the proposed regulations

Participants will be able to analyze the proposed regulations to help determine the potential impact to their organization.

New Pillar One, Pillar Two administrative guidance: Gaining definition

Date: July 18, 2024; 2:00 p.m. ET
Duration: 60 minutes
Host: Chad Hungerford
Presenters: Ryan Bowen, Sarah Custer, William C Zimmerman

1 Overview CPE credit | Taxes

On June 17, 2024, the Organization for Economic Co-operation and Development (OECD) released new Pillar One (Amount B) and Pillar Two guidance. Implementation of the two pillars remains a key focus area for jurisdictions and taxpayers. We’ll discuss:

• How the designation of certain “covered jurisdictions” and “qualifying jurisdictions” may affect the implementation of Amount B
  
• New Pillar Two implementation guidance
  
• The OECD process for determining whether local implementation of Pillar Two rules results in a jurisdiction having a “qualified” domestic minimum top-up tax

Participants will be able to discuss ongoing international tax streamlining and simplification efforts under Pillar One (Amount B), and Pillar Two implementation complexities faced by stakeholders.

Applying the new guidelines for domestic content bonus credit

Date: June 4, 2024; 11 a.m. ET
Duration: 60 minutes
Host: Adam Moehring
Presenters: Brian Americus, Jaime Park, Katie White

1 Overview CPE credit | Taxes

On May 16, 2024, the IRS released new guidance for the domestic content bonus credit for certain qualified facilities, energy projects, and energy storage technologies under sections 45, 45Y, 48, or 48E. During this webcast, we’ll discuss:

• Notice 2024-41, which provides a new safe harbor, and other details of credit eligibility
• How the marketplace is considering, supporting, and financing projects with domestic content in light of the new guidance
• Considerations and issues in analyzing eligibility
• Details of documentation and processes to compute the Domestic Cost Percentage and evaluate the Steel or Iron Requirement
  

In this session, participants will discover potential opportunities aligned to green business goals.

New Pillar Two Administrative Guidance: Clarity with complexity

Date: January 23, 2024; 2:00 p.m. ET
Duration: 60 minutes
Host: Adam Moehring
Presenters: Ryan Bowen, Sarah Custer, Bob Stack, and Carrie Walker

1 Overview CPE credit | Taxes

In December 2023, the OECD/G20 Inclusive Framework (IF) released additional guidance on the interpretation and application of the Pillar Two global minimum tax rules. The new Administrative Guidance focuses on the country-by-country reporting (CbC) safe harbor, including some expansion of the relief it provides. What does the new guidance clarify, and how complex is it? We’ll discuss:

• The highlights of the new rules as they relate to the CbC safe harbor

• The rules for pushing down GILTI taxes when controlled foreign corporations qualify for the CbC safe harbor

• Newly introduced anti-avoidance rules

Participants will examine the impact of the new Administrative Guidance on US and foreign companies.