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Course Details

Course Information
  • smart_display Format

    On-Demand

  • 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.


  • Live Online


    On Demand

$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

David N. de Ruig
Managing Director
KPMG Law, LLP
Seevun Dunckzar
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 a number of meaningful 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 budget reconciliation bill known as the OBBB. On July 1, 2025, the Senate passed its version of the bill, which made various amendments, including changes to the tax subtitle that was included in the House bill. On July 3, 2025, the House passed the Senate version of the bill without amendment, and the bill was signed into law by President Trump on July 4, 2025.


This new bill generally makes many of the international tax provisions from the 2017 Tax Cuts and Jobs Act (TCJA) permanent, including various aspects of the international provisions relating to 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.


Our panel 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 and multinational business operations, including FDII, GILTI, BEAT, and other key provisions, and provide tax planning considerations 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 are the next steps and planning considerations for tax counsel and advisers?