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Corporate Tax Update Related to U.S. International Tax Reform under the Tax Cuts and Jobs Act (TCJA)

 

Gain a better understanding of the major new international tax provisions related to the TCJA.

Many corporate tax practitioners must manage the implications of the international tax provisions created under the Tax Cut and Jobs Act (TCJA) that was signed into law on December 22nd, 2017. With the one-time transition tax still in recent memory, practitioners must now contend with the new world of U.S. territorial tax of foreign income with an alphabet soup of new guardrails such as FDII, GILTI, and BEAT. This topic will briefly identify the significant new U.S. international tax provisions, their interaction with the pre-legislation international provisions and how to calculate U.S. Federal tax on foreign income. Tax planning opportunities and practical tips will also be briefly mentioned in the material.

Agenda

Faculty

John P. Garcia, CPA, M.B.A.

John P. Garcia, CPA, M.B.A.

Corporate Tax Advisors

  • More than 25 years of experience providing services to major multinational corporations such as Billabong, Nixon, Targus, Marriott, Dial, Henkel, The University of Phoenix, and CPE, Inc
  • Conducts regular seminars and workshops on the following: Tax Aspects of the CARES Act, Accounting for Income Taxes – ASC 740/FAS 109; International Taxation; State and Local Taxation; and Uncertain Tax Positions – FIN 48 and Transfer Pricing
  • Wrote the SRR Journal, Fall 2016, How to Properly Capitalize Subsidiaries Without Getting Ensnared in the Earnings-Stripping Rules; California CPA magazine, June 2013, An Integrated Database Solution to Global Withholding Compliance; and Thomson Reuters, Corporate Taxation, December 2009, Green Corporate Tax Incentives-Wind Technologies
  • Member of Arizona Society of CPAs and AICPA
  • M.B.A. degree in international business; B.S. degree in accounting and finance, University of Maryland College Park
  • Can be contacted at 877-728-1400 or [email protected]
Ryan Gaglio

Ryan Gaglio

Stradling Yocca Carlson & Rauth, P.C.

  • Attorney with Stradling Yocca Carlson & Rauth, P.C.
  • Focuses on tax planning, tax controversy and transactional matters
  • Advises clients on the federal, state and local tax consequences of mergers and acquisitions, bankruptcies and workouts, executive compensation, as well as tax planning for inbound and outbound transactions, intercompany transfer pricing, foreign currency transactions, and other international tax matters
  • Published several articles and is the co-editor of a comprehensive tax treatise, Taxation of Securities Transactions “Overlooked Impact of Health Care Reform,” Daily Journal (August 31, 2012)
  • J.D. degree, Yale Law School; B.A. degree, Columbia College
  • Can be contacted at 949-725-4042 or [email protected]

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