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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

    Wednesday, April 1, 2020

  • 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.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax professionals and advisers with a practical guide to the recently issued IRS final regulations on the base erosion and anti-abuse tax (BEAT). The panel will discuss critical provisions of the new IRS final regulations, application to pass-through entities, determining aggregate groups, and Section 6038A reporting requirements. The webinar will also address gross receipts and base-erosion percentage tests, anti-abuse and recharacterization rules, and other crucial considerations.

Faculty

Joshua D. Odintz
Partner
Holland & Knight LLP

Mr. Odintz is the managing partner of the firm's Washington Tax Department. He held high-level government positions with both the U.S. Department of the Treasury and the Senate Finance Committee. He previously served as a Senior Advisor for Tax Reform to the Assistant Secretary at the U.S. Department of the Treasury, where he advised Senior Treasury officials on tax reform options and issues. He also served as the Chief Tax Counsel to the President’s National Commission on Fiscal Responsibility and Reform, and was instrumental in formulating the tax proposals that were contained in the Commission’s report, entitled the Moment of Truth. Additionally, he served as the Acting Tax Legislative Counsel at the Treasury.

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Anke Krueger
Managing Director
BDO USA

Ms. Krueger has been a member of the International Tax consulting group for more than 10 years. She consults on both inbound and outbound cross-border tax planning for public and privately-held companies.

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Description

On Dec. 2, 2019, the IRS issued detailed guidance on the Sec. 59A BEAT. The final regulations provide details on determining which taxpayers are subject to the BEAT rules and base-erosion payments, and minimum amount. They also address reporting and recordkeeping requirements.

The final regulations have a significant impact on corporations with substantial gross receipts that make payments to foreign related parties and corporations required to report under Secs. 6038A and 6038C. The regulations provide critical guidance and clarification on determining the application of BEAT to taxpayers, rules for the gross receipts test and base-erosion percentage test, computation of modified taxable income and the base-erosion minimum tax amount, and anti-abuse and recharacterization rules.

The final regulations also provide relief for nonrecognition transactions, a mechanism for waiving allowable deductions, rules regarding aggregate and consolidated groups, and other crucial items that tax counsel and advisers must consider. Furthermore, the IRS issued proposed regulations on the application of BEAT to partnerships in response to concerns expressed by practitioners.

Listen as our panel of experts discusses provisions of the new IRS final regulations, its application to pass-through entities, reporting requirements, and special rules and tests. The panel will offer planning techniques for taxpayers.

Outline

  1. Overview of final and additional proposed regulations
  2. Critical rules and tests
    1. Gross receipts and base-erosion percentage tests
    2. Anti-abuse and recharacterization rules
    3. Aggregate and consolidated group
  3. Application to pass-through entities
  4. Section 6038A reporting requirements and pitfalls to avoid
  5. Best practices and tax planning opportunities for taxpayers

Benefits

The panel will review these and other key issues:

  • Key provisions of the IRS final regulations on the BEAT for taxpayers
  • New rules on the application of BEAT to partnerships
  • Determining gross receipts and the base-erosion percentage test
  • New rules for anti-abuse and recharacterization
  • Rules for deciding aggregate and consolidated groups
  • Critical Section 6038A reporting challenges and methods to overcome them
  • Proposed waiver election

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Understand critical provisions of the IRS final regulations on BEAT for taxpayers
  • Ascertain rules for the application of BEAT to partnerships
  • Identify issues associated with determining gross receipts and the base-erosion percentage test
  • Recognize critical issues stemming from new regulations for anti-abuse and recharacterization
  • Identify challenges for determining aggregate and consolidated groups
  • Recognize Section 6038A reporting challenges and methods to overcome them

  • 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. Knowledge of, and familiarity with, the foreign-source income tax reporting rules and Controlled Foreign Corporations determination.

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.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).