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Course Details

Course Information
  • smart_display Format

    Live Online with Live Q&A

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, August 14, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

$347.00

This course is $0 with these passes:

CLE
CPE
ALL

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, multinational business operations, including proposed Section 899, FDII, GILTI, BEAT, and other key provisions, and provide tax planning strategies to optimize tax benefits and avoid tax pitfalls.

Faculty

Seevun Dunckzar (née Kozar)
Senior Manager
KPMG Law, LLP

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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Description

The One Big Beautiful Bill Act (OBBB) contains changes impacting international transactions, business operations, and investments for both individuals and companies. Tax counsel and advisers must recognize the potential impact of key tax provisions contained in the OBBB on clients with cross-border transactions and operations.

On May 22, 2025, the U.S. House of Representatives passed the OBBB. This new bill generally makes some international tax provisions from the 2017 Tax Cuts and Jobs Act (TCJA) permanent, including the international provisions global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), and base erosion and anti-abuse tax (BEAT). However, certain modifications and new provisions significantly impact U.S. international tax policy and tax planning.

The OBBB includes material changes to the international tax rules and the Tariff Act of 1930, including, but not limited to, (1) extending Section 250 deduction rates for FDII and GILTI and Section 59A for BEAT; (2) allowing taxpayers to currently deduct domestic research or experimental expenditures; and (3) new Section 899 to impose additional U.S. tax on income earned by non-U.S. persons in jurisdictions that impose discriminatory or extraterritorial taxes.

Listen as our panel discusses new tax law changes impacting international transactions, multinational business operations, including proposed Section 899, FDII, GILTI, BEAT, and other key provisions, as well as provides tax planning strategies to optimize tax benefits and avoid tax pitfalls.

Outline

I. Overview of the OBBB

II. Expansion of TCJA provisions

A. Section 250 deductions for FDII and GILTI

B. BEAT

C. Section 174 and Section 163(j)

III. New Section 899

A. Unfair foreign taxes

B. Tax rate increases

C. Modifications to BEAT

IV. 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 is the impact of new Section 899 on U.S. tax policy and tax planning?
  • What are the next steps and planning considerations for tax counsel and advisers?

NASBA Details

Learning Objectives 

After completing this course, you will be able to:

  • Identify extended TCJA provisions
  • Understand key international tax issues for non-U.S. citizens under Sec. 899
  • Determine the impact of recent legislation on U.S. tax policy
  • Ascertain planning strategies to mitigate tax liability for taxpayers
  • Decide how current legislation impacts deductions for multinational companies

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Working knowledge of partnership/corporate structure, international taxation, and acquisitions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.