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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Tuesday, February 25, 2025

  • schedule Time

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

  • timer Program Length

    110 minutes

Credit Information

  • 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).

$197.00
CPE
ALL

This webinar will review the key components of the new proposed PTEP (previously taxed earnings and profits) regulations for CFCs, international shareholders, and multinational entities. Our panel of astute international tax experts will address the updates made to Sections 959 and 961 and point out the issues the new regulations will resolve as well as those that are still problematic. They will recommend steps international practitioners need to take immediately to prepare for these modifications to the U.S. foreign taxation regime.

Faculty

Kodj Gbegnon
Principal
PwC

Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San Jose).  His practice focuses on tax planning for cross-border M&A and restructurings, IP integration, taxation of online / digital transactions and tax attribute planning (including foreign tax credits). Mr. Gbegnon is a member of the California Bar Association. 

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Cynthia Furmanek
Senior Manager
PwC

Ms. Furmanek is a senior manager in the International Tax Services practice at PwC’s Silicon Valley office. She advises multinational clients—primarily in the software and technology industry—on structuring global operations, foreign tax planning, cross-border acquisitions and reorganizations, and repatriation strategies. An attorney with experience in international tax since 2014, Ms. Furmanek specializes in managing foreign tax attributes, including foreign tax credits and earnings and profits. She combines her legal and tax expertise to help clients navigate complex cross-border tax considerations. Ms. Furmanek has written on international tax topics, including a recent article published in Tax Analysts.

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David Sotos
Principal
PwC

Mr. Sotos is principal and a member of PwC’s Washington National Tax practice, based in San Jose. His practice involves advising clients and PwC practice teams on a wide array of outbound and inbound international tax matters, including cross-border M&A, IP integration, foreign tax credits, dual consolidated losses, anti-deferral, and US tax treaties.

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Description

Described as highly-anticipated and overdue, the Treasury and IRS published proposed PTEP regulations (REG-105479-18) on Dec. 2, 2024. They offer much-needed clarification to extensive changes made under the Tax Cuts and Jobs Act (TCJA). TCJA added several new provisions, including GILTI, BEAT, FDII, and a Section 965 transition tax on previously untaxed foreign income. The PTEP rules are meant to circumvent double taxation when, for example, a foreign corporation distributes a dividend to a U.S. shareholder that has been previously taxed. As expected, the regulations are highly complex, leaving many questions unresolved and creating the need for additional clarification.

Significant provisions include revisions under IRC Section 959 requiring PTEP accounts at the shareholder level in addition to the foreign corporation. The foreign corporation's PTEP is divided into 10 groups and two subgroups and maintained in the foreign corporation's functional currency. Shareholders must maintain dollar basis and tax pools annually. Also key, the newly proposed regulations provide new rules for calculating lower-tier basis and have added the term "derived basis" and provisions for basis adjustments for lower-tier CFC and partnership interests owned directly by another partnership.

The proposed PTEP regulations will be effective retroactively when and if finalized, and the reach of these regulations is considerable. Tax practitioners serving multinational taxpayers need to prepare for its impact.

Listen as our panel of authoritative international tax veterans explains the effect of the long-awaited PTEP regulations on multinational entities.

Outline

  1. Introduction
  2. PTEP accounting
  3. Shareholder accounts
  4. Basis adjustments
  5. Ordering rules
  6. Partnership rules
  7. Consolidated return rules
  8. Foreign currency provisions
  9. Other components
  10. Effective date
  11. Implementation

Benefits

The panel will cover these and other critical issues:

  • Complying with shareholder account maintenance provisions under the proposed PTEP regulations
  • Calculating lower-tier basis under the new regulations
  • Steps multinational entities and their advisers should take to prepare for foreign regulation changes
  • Key issues not addressed in the proposed PTEP regulations

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify issues not addressed relative to PTEP in the proposed regulations
  • Determine how to maintain shareholder PTEP accounts under the newly proposed regulations
  • Decide how CFCs and shareholders should prepare for impending changes
  • Ascertain when the proposed regulations are effective

  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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).