New Proposed PTEP Regulations: Maintaining Shareholder Accounts, Tracking Basis Adjustments, Implementation
A live 110-minute CPE webinar with interactive Q&A
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.
Outline
- Introduction
- PTEP accounting
- Shareholder accounts
- Basis adjustments
- Ordering rules
- Partnership rules
- Consolidated return rules
- Foreign currency provisions
- Other components
- Effective date
- 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
Faculty
Surbhi Bordia
Partner
Armanino
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact... | Read More
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact international companies’ operations and puts tax efficient structures in place for her clients. Ms. Bordia’s hands-on experience in international tax, IP migration planning and legal entity rationalizations make her an expert consultant and key team player for clients in mergers and acquisitions. Ms. Bordia’s focus areas include GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credits, subpart F, withholding tax, investments in U.S. property, FX gains and losses, treaty-related issues, outbound transfers and permanent establishment and profit attribution rules.
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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.... | Read More
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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Kodj Gbegnon
Principal
PwC
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San... | Read More
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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