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CARES Act, NOL Rules, IRS Guidance: Critical Tax Considerations and Mitigation Planning for Taxpayers

Impact of Pandemic on Cash and Liquidity, BEAT, GILTI, FDII, Sec. 965 Transitions Tax

Recording of a 90-minute premium CLE/CPE webinar with Q&A

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Conducted on Tuesday, June 2, 2020

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will provide guidance to tax counsel and advisers on critical tax considerations amid the COVID-19 pandemic. The panel will discuss tax implications and potential opportunities under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, recent IRS guidance, NOL rules, and challenges under the BEAT, GILTI, FDII, and transition tax rules. The panel will also examine additional tax considerations and offer mitigation planning techniques under current tax law and the CARES Act and state and local tax considerations.


The spread of COVID-19 has significantly impacted most companies and individual taxpayers. The coronavirus pandemic presents many federal and state tax challenges forcing tax professionals to implement measures and mitigation techniques for taxpayers.

The current economic impact of COVID-19 requires taxpayers to focus on finding tax relief under current federal and state tax law. A complete understanding of rules regarding the treatment and use of NOLs along with international tax provisions of the Code, such as BEAT, GILTI, FDII, and transition tax rules, are essential for mitigation planning in times of a crisis.

On Mar. 27, 2020, the CARES Act was enacted, providing critical tax provisions to assist companies and individual taxpayers. It gives an employee retention tax credit to certain employers, a deferral of self-employment taxes, rules on NOL carryback and 80% limitations, and other items critical to most taxpayers. Also, the IRS has and continues to issue guidance concerning employee benefits, the treatment of the payment or reimbursement of certain expenses, and other issues faced by companies.

Listen as our panel discusses the critical U.S. and international tax considerations for taxpayers in light of the spread of COVID-19 and essential takeaways of the CARES Act, as well as offers mitigation planning techniques under current tax law.



  1. Tax implications of the coronavirus pandemic
  2. Coronavirus Aid, Relief, and Economic Security (CARES) Act
  3. Challenges under BEAT, GILTI, FDII, and transition tax rules
  4. Critical State and Local Tax Implications


The panel will review these and other key issues:

  • What are the tax issues for taxpayers and businesses as a result of the spread of COVID-19?
  • What are the key tax considerations for businesses after the recently enacted CARES Act?
  • How are payments or reimbursement of employee expenses treated for tax purposes?
  • What are the tax implications of employees working remotely outside of the jurisdiction of their employer?
  • What tax credits or relief is available to businesses and the self-employed?
  • What is the impact on NOL rules?
  • What are the challenges of BEAT, GILTI, FDII, and transition rules as a result of the coronavirus pandemic?
  • What are the state and local tax implications?


Barnett, Robert
Robert S. Barnett, JD, MS (Taxation), CPA

Capell Barnett Matalon & Schoenfeld

Mr. Barnett’s practice is highly concentrated in the areas of taxation, trusts, estates, corporate and...  |  Read More

Davis, J. Brian
J. Brian Davis

Baker & Hostetler

Mr. Davis is a partner in the Washington, D.C. office of BakerHostetler, and head of the firm’s international tax...  |  Read More

Semes, Michael
Michael J. Semes

Of Counsel
Baker & Hostetler

Mr. Semes works closely with clients to resolve their complex tax issues. Drawing from his experiences as a senior...  |  Read More

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