2025 Tax Reform for Non-U.S. Investors and Companies: International Tax Provisions in the One Big Beautiful Bill Act
Key Issues Stemming From the New Tax Bill, Section 899, FDII, GILTI, BEAT, and More
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax counsel and advisers with a review of the application and impact of the new tax bill on international taxation and planning. The panel will discuss new tax law changes impacting international transactions, multinational business operations, including proposed Section 899, FDII, GILTI, BEAT, and other key provisions, and provide tax planning strategies to optimize tax benefits and avoid tax pitfalls.
Outline
- Overview of the OBBB
- Expansion of TCJA provisions
- Section 250 deductions for FDII and GILTI
- BEAT
- Section 174 and Section 163(j)
- New Section 899
- Unfair foreign taxes
- Tax rate increases
- Modifications to BEAT
- Planning considerations and best practices for tax counsel
Benefits
The panel will discuss these and other key issues:
- How does the OBBB modify international tax law provisions?
- What provisions of the TCJA does the OBBB seek to modify or expand?
- How do the new provisions impact taxpayers with multinational transactions and operations?
- What is the impact of new Section 899 on U.S. tax policy and tax planning?
- What are the next steps and planning considerations for tax counsel and advisers?
Faculty

Mohsen Ghazi
Partner
McDermott Will & Emery
Mr. Ghazi advises family offices, fund sponsors, and high-net-worth individuals on the tax-efficient structuring... | Read More
Mr. Ghazi advises family offices, fund sponsors, and high-net-worth individuals on the tax-efficient structuring of investment funds and family office vehicles, both domestically and internationally. He focuses his family office practice on the formation and restructuring of family offices and private trust companies; the establishment of incentive equity programs for key personnel; and advising on pre-immigration planning, expatriation strategies, and related matters involving international and partnership taxation.
CloseCannot Attend August 14?
Early Discount (through 07/18/25)
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.