eCourse
International Tax Overview and Issues after TCJA for Oil and Gas
Contains material from Jan 2020
International Tax Overview and Issues after TCJA for Oil and Gas
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Session 1: Overview of the International Tax System for the Oil and Gas Industry After the TCJA - Hear an overview of the international provisions following the 2017 TCJA, including the new GILTI, FDII, and BEAT provisions as well as the impact on the pre-existing international provisions. Examine the impact of the TCJA on the oil and gas industry and how the changes may affect the business operations and tax planning of companies in the oil and gas business, including the tax-favored treatment of FOGEI income in contrast to the treatment of FORI income, which generally remains subject to its pre-2018 treatment.
Session 2: Continuation of FTC Issues - Listen to a discussion about foreign tax credit issues post-TCJA, including the new section 960 rules, expense allocation regulations, and foreign tax credit basketing.
Session 3: GILTI, FDII and the BEAT: Tax Planning in a Post-Reform World - Hear a summary of the new rules regarding foreign source dividends, Global Intangible Low-Taxed Income, Foreign-Derived Intangible Income, and Subpart F. Also, review how tax planning has changed since the 2017 tax reforms and how these new rules can be managed from a tax planning standpoint.
Session 2: Continuation of FTC Issues - Listen to a discussion about foreign tax credit issues post-TCJA, including the new section 960 rules, expense allocation regulations, and foreign tax credit basketing.
Session 3: GILTI, FDII and the BEAT: Tax Planning in a Post-Reform World - Hear a summary of the new rules regarding foreign source dividends, Global Intangible Low-Taxed Income, Foreign-Derived Intangible Income, and Subpart F. Also, review how tax planning has changed since the 2017 tax reforms and how these new rules can be managed from a tax planning standpoint.
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1.
Overview of the International Tax System for the Oil and Gas Industry After the TCJA (Jan 2020)
Carol P. Tello, Anne Devereaux, Bret Wells, Steven C. Wrappe
1.00
0.00
0.00
Session 1
—60 mins
Overview of the International Tax System for the Oil and Gas Industry After the TCJA (Jan 2020)
Hear an overview of the international provisions following the 2017 TCJA, including the new GILTI, FDII, and BEAT provisions as well as the impact on the pre-existing international provisions. Examine the impact of the TCJA on the oil and gas industry and how the changes may affect the business operations and tax planning of companies in the oil and gas business, including the tax-favored treatment of FOGEI income in contrast to the treatment of FORI income, which generally remains subject to its pre-2018 treatment.
Originally presented: Nov 2019 Oil and Gas Tax Conference
Carol P. Tello,
Eversheds Sutherland LLP - Washington, DC
Anne Devereaux,
Office of Chief Counsel (INTL), Internal Revenue Service - Washington, DC
Bret Wells,
University of Houston Law Center - Houston, TX
Steven C. Wrappe,
Grant Thornton LLP - Washington, DC
Show session details
2.
Continuation of FTC Issues (Jan 2020)
Moshe Spinowitz, Michael J. Caballero, Karen J. Cate, Glenn Leishner, Danielle Rolfes
1.25
0.00
0.00
Session 2
—74 mins
Continuation of FTC Issues (Jan 2020)
Discuss foreign tax credit issues post-TCJA, including the new section 960 rules, expense allocation regulations, and foreign tax credit basketing.
Originally presented: Nov 2019 Oil and Gas Tax Conference
Moshe Spinowitz,
Skadden, Arps, Slate, Meagher & Flom LLP - Boston, MA
Michael J. Caballero,
Covington & Burling - Washington, DC
Karen J. Cate,
Internal Revenue Service - Washington, DC
Glenn Leishner,
Anadarko Petroleum Corporation - The Woodlands, TX
Danielle Rolfes,
KPMG LLP - Washington, DC
Show session details
3.
GILTI, FDII and the BEAT: Tax Planning in a Post-Reform World (Jan 2020)
Edward C. Osterberg Jr., Layla J. Asali, Nicholas J. DeNovio, Carol B. Tan, Gabriel Zimmerman
1.25
0.00
0.00
Session 3
—71 mins
GILTI, FDII and the BEAT: Tax Planning in a Post-Reform World (Jan 2020)
Hear a summary of the new rules regarding foreign source dividends, Global Intangible Low-Taxed Income, Foreign-Derived Intangible Income, and Subpart F. Also review how tax planning has changed since the 2017 tax reforms and how these new rules can be managed from a tax planning standpoint.
Originally presented: Nov 2019 Oil and Gas Tax Conference
Edward C. Osterberg Jr.,
Mayer Brown LLP - Houston, TX
Layla J. Asali,
Miller & Chevalier Chartered - Washington, DC
Nicholas J. DeNovio,
Latham & Watkins LLP - Washington, DC
Carol B. Tan,
Special Counsel, IRS Associate Chief Counsel (International), Internal Revenue Service - Washington, DC
Gabriel Zimmerman,
Chevron - Houston, TX