IRS PTEP Regulations: New Proposed Rules, Tracking Basis, Maintaining Shareholder Accounts, Sections 959 and 961
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
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.
Outline
- Overview of current PTEP regulations
- Changes under the proposed regulations
- Shareholder accounts
- Basis adjustments
- Ordering rules
- Partnership rules
- Foreign currency provisions
- Other components
- 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
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... | Read More
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.
Close
Morgan Hann
Managing Director, National Tax Office
BDO USA
Mr. Hann is the Managing Director, National Tax Office-Partnerships at BDO USA.
| Read MoreMr. Hann is the Managing Director, National Tax Office-Partnerships at BDO USA.
Close
Michael Masciangelo, CPA
Tax Partner; International Tax Services Practice Leader
BDO USA
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S.... | Read More
Mr. Masciangelo is responsible for international tax strategy development, including working with the firm’s U.S. offices and hub markets to develop and implement strategic cross-border solutions. He has more than 25 years of experience at a Big Four firm in corporate and international tax. Mr. Masciangelo has a combination of firmwide technical leadership and market-facing roles.
Close
Cannot Attend April 8?
Early Discount (through 03/14/25)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.