BarbriSFCourseDetails
  1. keyboard_arrow_leftBack

Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Tuesday, April 8, 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.

$347.00
CLE
ALL

This CLE/CPE webinar will provide tax professionals an in-depth analysis of key components of the new proposed PTEP (previously taxed earnings and profits) regulations for multinational entities and their shareholders. The panel will discuss updates to Sections 959 and 961, issues stemming from the new regulations, and next steps and key considerations for international practitioners to prepare for these modifications to the U.S. foreign taxation regime.

Faculty

Neil Feinstein
Managing Director, National Tax Office, International Tax Service
BDO USA

Mr. Feinstein has over 30 years of experience in advising multinational companies and large privately held companies on domestic and international mergers and acquisitions and other business transactions, structuring of international operations (including tax efficient supply chains), financial products, and foreign currency transactions, as well as on other tax matters. His clients have included companies in the manufacturing, pharmaceuticals, specialty chemicals, and financial services industries, among other industries. Mr. Feinstein joined BDO in November 2022 after retiring as a managing director from Deloitte Tax LLP in 2020. Prior to joining Deloitte in 1996, he was partner in the law firm of Duane, Morris & Heckscher and in the law firm of Zapruder & Odell. Mr. Feinstein began his career as a tax associate at the law firm of Morgan, Lewis & Bockius.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Tiffany Ippolito
Managing Director
BDO USA

Ms.Ippolito has over 15 years of experience in taxation, which includes over 12 years of public accounting experience providing international tax consulting and compliance services to multinational public and private companies. As part of BDO’s National Tax Office, she specializes in providing international tax consulting services to U.S. and foreign multinationals, including teaming with BDO's International Tax Services team, nationally, to help clients navigate international tax calculations and filings required under the Tax Cuts and Jobs Act, group reorganizations and restructurings, international mergers and acquisitions and due diligence, identifying international tax planning opportunities, managing internal and external risk, as well as monitoring pending U.S. international tax legislation.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Morgan Hann
Managing Director, National Tax Office
BDO USA

Mr. Hann is the Managing Director, National Tax Office-Partnerships at BDO USA. 

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Wilson Brakefield
BDO USA

Description

On Dec. 2, 2024, the Treasury and IRS published highly-anticipated proposed PTEP regulations (REG-105479-18). Tax professionals must understand the impact of these proposed regulations and their interplay with several TCJA provisions, such as GILTI provisions, the dividend-received deduction under Section 245A, and the Section 965 transition tax provisions on PTEP.

The PTEP rules are meant to avoid double taxation when, for example, a foreign corporation distributes a dividend to a U.S. shareholder that has been previously taxed. The proposed regulations include revisions under Section 959 requiring PTEP accounts at the shareholder level in addition to the foreign corporation. Shareholders must maintain dollar basis and tax pools annually. Furthermore, the proposed regulations provide new rules for calculating lower-tier basis for CFCs and partnerships.

As expected, the regulations are highly complex, leaving many questions unresolved and creating the need for additional clarification. Once the regulations are finalized they will be effective retroactively. Tax professionals serving multinational entities need to prepare for its impact.

Listen as our panel discusses the effect of the long-awaited PTEP regulations on multinational entities, updates to Sections 959 and 961, key issues stemming from the new regulations, and next steps for tax practitioners.

Outline

  1. Overview of current PTEP regulations
  2. Changes under the proposed regulations
  3. Shareholder accounts
  4. Basis adjustments
  5. Ordering rules
  6. Partnership rules
  7. Foreign currency provisions
  8. Other components
  9. Effective date and implementation

Benefits

The panel will cover these and other key issues:

  • What are the key provisions of recently proposed PTEP regulations?
  • How must shareholder accounts be maintained under the proposed PTEP regulations?
  • How do you calculate lower-tier basis under the new regulations?
  • Steps multinational entities and their advisers should take to prepare for the new PTEP rules
  • Key issues not addressed in the proposed PTEP regulations