This course will provide a recap of some major international tax rules currently in effect, and several international tax proposals from the current Administration, including, but not limited to FDII (Section 250) regulations (briefly), the GILTI (Section 951A) (briefly), and Section 245A foreign DRD. The format of this course will be more high-level and less in-depth because of the timing and number of topics covered. This CCH CPE webinar will also include a discussion of some of the proposed international tax provisions currently being contemplated within Congress and the White House.
Please read IRC Sections 1, 11, 951, 951A, 954, 250 prior to the course.
Publication Date: December 2021
Designed For
Experienced international tax staff through international tax director level interested in or already practicing international taxation.
Topics Covered
- Key international tax provisions post-TCJA
- Select international tax proposals by HR & WH
- Select International Tax Proposals (3 Sections)
- U.S. International Tax Updates — Planning Summary
Learning Objectives
- Identify major, current international tax technical provisions
- Recognize some major considerations for utilizing C corporations in the international tax context
- Recognize select international tax proposals and related income tax planning considerations
- Identify what takes precedence when determining taxation of controlled foreign corporations (CFCs)
- Recognize who benefits the most from the foreign-derived intangible income (FDII) deduction
- Identify what the international tax proposals includes in the Build Back Better Act
- Recognize which business is included in the scope of Pillar One
- Identify the percentage Pillar Two seeks to impose a global minimum tax
Level
Update
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
Experienced international tax staff through international tax director level interested in or already practicing international taxation.
Advance Preparation
None
Instructor
Adnan Islam
Adnan Islam, Esq., CPA, is a partner with Friedman LLP, co-chair of the International Tax Services group, and a leader of its Blockchain/Digital Asset Transactions group. He has nearly 17 years of public accounting experience as a licensed tax attorney and CPA. Adnan has served an array of industries and clients ranging from startups to publicly traded companies including Avon, MeadWestVaco, Honeywell, Verizon, Agilent, SunGard, Booz Allen, IDT, SunGard, AMEX, OUAI, IBISWorld, Conair, Grayscale, DCG, and various blockchain and crypto (digital asset) companies, exchanges, and private equity and hedge funds. Adnan specializes in cross-border strategies, comprehensive inbound tax services, global information reporting, and structuring for crypto funds, companies, and exchanges.
As an industry thought leader, Adnan has lectured on international tax at TEI events, AICPA seminars and served as an adjunct professor for Golden Gate University Master’s in Tax curriculum. Adnan’s expertise includes advising clients at all stages of business and restructuring, with respect to FDII, GILTI, 245A DRD, subpart F, PFICs, and other issues. Additionally, Adnan empowers his clients’ decision-making and improves their supply chain and operational efficiency, including the use of holding companies, treaty country networks, and affirmative tax planning through comparative rate modeling.
Adnan is a licensed attorney admitted to practice law in New Jersey, DC, and California and a Certified Public Accountant (NY & CA). He holds a Juris Doctor (J.D.) and an M.B.A. from Rutgers University; an LL.M. in Taxation from the New York University School of Law; a blockchain business certificate from MIT; and is currently enrolled in Georgetown Law's Tax LL.M. (International Tax Certificate) program. Adnan has been admitted as a Certified Legal Specialist in Tax Law by the State Bar of California. He also is an (inactive) enrolled agent (through IRS exam).