IRS PTEP Regulations: New Proposed Rules, Tracking Basis, Maintaining Shareholder Accounts, Sections 959 and 961
Recording of a 90-minute premium CLE/CPE video webinar with 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
Wilson Brakefield
Senior Manager
BDO USA
Mr. Brakefield is a Senior Manager, International Tax at BDO USA. He has experience working with... | Read More
Mr. Brakefield is a Senior Manager, International Tax at BDO USA. He has experience working with international tax law and regulations, mergers and acquisitions, private equity, Subchapter C, and partnership taxation. Mr. Brakefield is a strong business development professional with an LLM focused in Taxation from New York University School of Law and a JD/MBA from the University of Richmond.
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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.
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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.
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Tiffany Ippolito, JD, LLM
Managing Director
BDO USA
Ms.Ippolito has over 15 years of experience in taxation, which includes over 12 years of public accounting experience... | Read More
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.
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