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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

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Thursday, August 14, 2025

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, July 18, 2025

or call 1-800-926-7926

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.

Description

The One Big Beautiful Bill Act (OBBB) contains changes impacting international transactions, business operations, and investments for both individuals and companies. Tax counsel and advisers must recognize the potential impact of key tax provisions contained in the OBBB on clients with cross-border transactions and operations.

On May 22, 2025, the U.S. House of Representatives passed the OBBB. This new bill generally makes some international tax provisions from the 2017 Tax Cuts and Jobs Act (TCJA) permanent, including the international provisions global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), and base erosion and anti-abuse tax (BEAT). However, certain modifications and new provisions significantly impact U.S. international tax policy and tax planning.

The OBBB includes material changes to the international tax rules and the Tariff Act of 1930, including, but not limited to, (1) extending Section 250 deduction rates for FDII and GILTI and Section 59A for BEAT; (2) allowing taxpayers to currently deduct domestic research or experimental expenditures; and (3) new Section 899 to impose additional U.S. tax on income earned by non-U.S. persons in jurisdictions that impose discriminatory or extraterritorial taxes.

Listen as our panel discusses new tax law changes impacting international transactions, multinational business operations, including proposed Section 899, FDII, GILTI, BEAT, and other key provisions, as well as provides tax planning strategies to optimize tax benefits and avoid tax pitfalls.

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Outline

  1. Overview of the OBBB
  2. Expansion of TCJA provisions
    1. Section 250 deductions for FDII and GILTI
    2. BEAT
    3. Section 174 and Section 163(j)
  3. New Section 899
    1. Unfair foreign taxes
    2. Tax rate increases
    3. Modifications to BEAT
  4. 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

Ghazi, Mohsen
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

Attend on August 14

Early Discount (through 07/18/25)

See NASBA details.

Cannot 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.

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