The Tax Reform’s GILTI and FDII Provisions: Opportunities and Challenges for Businesses Explored
The recent enactment of the Tax Cuts and Jobs Act paved way for numerous concepts which provided a sweeping change to the taxation landscape. The Foreign Derived Intangible Income (FDII) and the Global Intangible Low Tax Income (GILTI) are two new provisions under the said Act that determine how U.S. companies should deal with taxation issues.
Just like any other new provisions introduced on a platform, GILTI and FDII provide opportunities for businesses to improve their system with regards to taxation matters. However, alongside such opportunities are challenges that threaten businesses. It is therefore imperative for an industry to devote time in understanding the rules surrounding these new provisions to prepare for its probable implications in their business.
Our panel of key thought leaders and practitioners will offer a discussion of the fundamentals as well as updates regarding the latest and significant issues surrounding the tax reform’s GILTI and FDII provisions and aim to help in avoiding common pitfalls and risk issues on the aforementioned provisions.
This LIVE webcast will discuss the following key provisions:
- Tax Cuts and Jobs Act: An Overview
- GILTI and FDII Provisions
- Opportunities for Businesses
- Potential Implications to Businesses
- Analysis of Critical Issues and Challenges
Justin Kuczmarski, MBA, CPA, CVA, CIRA, ABV, President
NAV Valuation & Advisory LLC
- How U.S. firms have reacted so far to FDII
- IP is returning to the U.S.
- Examples from 10-K filings
- Press releases from large public companies
- Planning obstacles
- What we are hearing
- Advice on how to stay on the cutting-edge of documentation
- Examples since enactment
- Planning obstacles
- Minority Interest
- Internal Controls
- Information Technology
- Key Lessons to Remember in the First Year of Compliance
- Closing Thoughts
James Guadiana, Partner
- Territorial Tax Regime Introduced
- Mandatory Inclusion of Post-1986 Earnings and Profits
- Subpart F Modified
- Modification of stock attribution rules for determining CFC status
- Modification of definition of United States shareholder
- Elimination of requirement that corporation must be controlled for 30 days before subpart F inclusions apply
- Repeal of Foreign Base Company Oil-Related Income
- Global Intangible Low-Taxed Income
- Computation of GILTI
- US Shareholder a C Corporation
- US shareholder not a C Corporation
- Foreign-Derived Intangible Income
- Deductions for Foreign-Derived Intangible Income
- Looking at GILTI and FDII together- A “stick and carrot analysis”
Who Should Attend:
- Tax Attorneys
- Tax Executives
- International Tax Attorneys
- Tax Directors
- Tax Consultants
- Finance Executives
- Other Related/Interested Professionals
Mr. Justin Kuczmarski, MBA, CPA, CVA, CIRA, ABV, CFF, is the President of NAV Valuation & Advisory LLC (“NAV”). Prior to founding NAV, Mr. Kuczmarski served as a NYC Practice Leader in Financial Advisory Services for a top 10 accounting and advisory firm. He also has senior M&A investment banking experience as a Valuation Practice Leader for a leading M&A boutique bank.
In 2016, Mr. Kuczmarski was a recipient of the NACVA 40 Under 40 from the nation's leading valuation association, the National Association of Certified Valuation Analysts (NACVA). Mr. Kuczmarski is the sole author of the 300-page guidebook entitled The Executive’s Guide to Business Valuation: Essentials for Advisors and Business Owners.
Mr. Kuczmarski received a B.A. in Politics from Princeton University. He also received an dual MBA in both Finance and Professional Accountancy from Fordham University's Gabelli School of Business in both Finance and Professional Accountancy, where attended on an academic fellowship in both departments.
Mr. Justin Kuczmarski, MBA, CPA, CVA, CIRA, ABV, CFF, is the President of NAV Valuation & Advisory LLC (“NAV”). Prior …
Jim Guadiana focuses his practice on the tax aspects of domestic and international transactions and investments. He serves as advisor to public and privately-held multinational companies and investment firms with regard to their operations and investments in the United States. Jim also has extensive experience as tax advisor to a number of public corporations listed on the London, Hong Kong, and Toronto stock exchanges. Jim is respected domestically and internationally for his ability to identify and resolve unique and complex tax issues in domestic and cross-border investments in a myriad of fields. Jim also has represented clients before U.S. tax agencies and U.S. tax courts.
Jim routinely advises clients on the establishment of transfer pricing policies, and assists clients in implementing beneficial cost-sharing and other arrangements. He counsels public and private companies on preservation of net operating losses and provides planning on various cross-border sales of physical commodities and related hedging transactions. Jim instructs issuers and investment banks regarding the treatment of foreign corporations as to their status, or avoidance of status, as passive foreign investment companies (“PFICs”). He structures multinational executive compensation programs to achieve optimum tax benefits for employers and employees in multiple jurisdictions. Jim advises clients on the tax aspects of transfers of proprietary technology, including patents. He counsels multinational families with regard to their global investments, business activities and U.S. tax compliance requirements.
Jim Guadiana focuses his practice on the tax aspects of domestic and international transactions and investments. He serves as advisor …
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Method of Presentation:
On-demand Webcast; Group-Internet Based
General Knowledge in Tax Law
NY Category of CLE Credit:
Areas of Professional Practice
NASBA Field of Study:
Taxes - Technical
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