Keeping Up With Developments Around GILTI, FDII and BEAT
Three provisions introduced by tax reform have proven to be highly significant for multinational businesses as they directly impact established business models: the global intangible low-taxed income (GILTI), the foreign-derived intangible income (FDII), and the base erosion and anti-abuse tax (BEAT).
In this webinar we will recap the latest guidance (final and proposed) from the IRS on these three provisions. We will discuss how these provisions impact businesses in different industries. We will highlight gaps in IRS guidance and what are potential benefits as well as compliance risks that corporate tax leaders should be aware of. You will gain practical insights on how your peers in multinational corporations tackled the challenges of adjusting to the new code.
- Gain meaningful insights into the latest regulations from the US Treasury and IRS to date
- Learn about new best practices to implement tax-effective corporate structures across borders
- Understand how to maximize the benefits of the new regulations for your company while simultaneously minimizing compliance risks
Corporate tax professionals with an interest in U.S.-international tax
BDO USA, LLP
Joe Calianno is a tax partner and serves as the firm’s International Technical Tax Practice Leader in BDO’s National Tax Office. He practices in all areas of international taxation. Prior to joining BDO, Joe was a partner with Grant Thornton’s National Tax Office and served as the firm’s International Technical Tax Practice Leader for over 10 years. He previously served as Special Counsel to the Deputy Associate Chief Counsel (International) in the Office of Chief Counsel, Internal Revenue Service. As Special Counsel, he served as a technical advisor to the Associate and Deputy Associate Chief Counsel (International) and was involved in reviewing international tax regulations, revenue rulings, Notices, TAMs, PLRs, and providing technical advice to IRS field offices. He also spent several years in private practice at a large law firm and PWC’s National Tax Office advising clients in several areas of tax law, including international, corporate and partnership taxation.
Miller & Chevalier
Loren Ponds focuses her practice on federal tax policy, providing strategic counsel to clients on legislative, regulatory, and other policy matters, transfer pricing, and broader international tax matters. She advises clients on the impacts of tax policy, such as the implementation of the Tax Cuts and Jobs Act of 2017 (TCJA) and, in particular, issues related to technical corrections and administrative guidance.
Ms. Ponds also maintains a transfer pricing and international tax practice, and advises clients on Advance Pricing Agreements, MAP negotiations, and other matters before the Internal Revenue Service; intangible property transactions; and other international tax issues.
Prior to joining Miller & Chevalier, Ms. Ponds served as Majority Tax Counsel to the U.S. House of Representatives Committee on Ways and Means, where she developed, analyzed, and refined the international tax provisions of the TCJA.
Previously, Ms. Ponds served in Ernst & Young LLP’s National Tax Department with a focus on international tax services, where she counseled multinational companies on tax planning projects, including intellectual property planning, supply chain optimization, and restructurings. Fluent in French and German, Ms. Ponds worked abroad as Ernst & Young’s Global Transfer Pricing Operations Manager in Düsseldorf, Germany.
Principal, Corporate Group, Washington National Tax
KPMG LLP (U.S.)
Clarissa Potter has more than 25 years of experience in federal income tax, including in the government and in the private sector, with particular focus on international tax issues and financial institutions and products. She has extensive background in restructuring international businesses, foreign tax credit planning, domestic and international mergers and acquisitions, transfer pricing issues, and tax policy.
Before joining KPMG, she was Deputy Director of Tax and Head of Global Tax Strategy at American International Group, Inc., where she directed a globally integrated tax strategy and transfer pricing group a time of significant change.
Clarissa previously served with the IRS, including as Deputy Chief Counsel (Technical) and Acting Chief Counsel. She led the IRS Chief Counsel’s Office during the 2008-2009 financial crisis, martialing IRS resources to respond to constant challenges and working with all parts of the U.S. executive and legislative branches to help protect the U.S. economy. Clarissa has an AB degree from Miami University and a JD degree from Yale Law School. She is a member of the New York Bar Association and the American Bar Association.