The true tax reform part of the Tax Cuts and Jobs Act (“TCJA”) was in the international tax arena. This session will discuss the various components of that reform including the new GILTI regime and the GILTI proposed regulations, the effect of GILTI on non-corporate taxpayers, the base erosion anti abuse tax (and regulations, if available), the new deduction for “foreign derived intangible income,” the new Code section 245A participation exemption and the treatment of controlled foreign corporations (“CFCs”) in a post TCJA world. In all this we will focus on 2018 IRS guidance and prospects for future guidance in 2019 and beyond.
The webinar will discuss changes from TCJA to:
- The new GILTI regime
- The new BEAT regime
- The new FDII regime
- The new participation exemption
Thomas Humphreys is a partner in Mayer Brown’s New York office and a member of the Tax Transactions & Consulting practice. He has extensive experience with the tax aspects of capital markets transactions; financial instruments; real estate investment trusts; mergers and acquisitions; bankruptcy and reorganization; tax controversy, including transfer pricing; and international transactions. Thomas also works with investment banks and issuers on developing new financial products.
Remmelt Reigersman is a partner in Mayer Brown’s Palo Alto office and a member of the Tax Transactions & Consulting practice. He concentrates his practice on federal and international tax matters. Remmelt advises on a wide variety of sophisticated capital markets transactions and represents issuers, investment banks/financial institutions and investors in financing transactions, including public offerings and private placements of equity, debt and hybrid securities, as well as structured products. Remmelt's areas of experience also include restructurings (both in and out of bankruptcy), debt and equity workouts, domestic and international mergers, acquisitions, reorganizations and joint ventures.
Linda J. O’Brien is the Editorial Lead for Legal Tax and Emerging Practice Areas on the Cheetah platform in the Wolters Kluwers Legal & Regulatory U.S. She has been with the company since 1997. Linda’s primary area of content expertise is in federal tax. She also has been a writer/analyst for daily news and monthly publications in the antitrust and intellectual property practice areas. Her publication credits include the Antitrust Law Daily, IP Law Daily, Trade Regulation Reporter, and Advertising Law Guide. Previously, Linda managed editorial groups which produced and maintained the daily federal tax news service and numerous legal and accounting subscription, book, and newsletter publications. Her publication credits in the tax practice area include the U.S. Master Tax Guide, Federal Tax Guide, Tax Planning Strategies, Federal Tax Course, as well as several law, explanation and analysis publications on tax legislation. Linda graduated from the John Marshall Law School and has an undergraduate degree in accounting from the University of Illinois and a LL.M. in Taxation from IIT Chicago-Kent College of Law.