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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 (in 4 days)

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

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 and multinational business operations, including foreign-derived intangible income (FDII), global intangible low-taxed income (GILTI), base erosion and anti-abuse tax (BEAT), and other key provisions, and provide tax planning considerations to optimize tax benefits and avoid tax pitfalls.

Description

The One Big Beautiful Bill Act (OBBB) contains a number of meaningful 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 budget reconciliation bill known as the OBBB. On July 1, 2025, the Senate passed its version of the bill, which made various amendments, including changes to the tax subtitle that was included in the House bill. On July 3, 2025, the House passed the Senate version of the bill without amendment, and the bill was signed into law by President Trump on July 4, 2025.

This new bill generally makes many of the international tax provisions from the 2017 Tax Cuts and Jobs Act (TCJA) permanent, including various aspects of the international provisions relating to GILTI, FDII, and BEAT. However, certain modifications and new provisions significantly impact U.S. international tax policy and tax planning.

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 are the next steps and planning considerations for tax counsel and advisers?

Faculty

Kozar, Seevun
Seevun Dunckzar

Senior Manager
KPMG

Ms. Dunckzar provides strategic advice to national clients from a wide variety of industries, including...  |  Read More

de Ruig, David
David N. de Ruig

Managing Director
KPMG

-

 |  Read More
Attend on August 14

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Cannot Attend August 14?

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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