New IRS Base Erosion and Anti-Abuse Tax (BEAT) Final Regulations
Sec. 6038A Reporting Issues, Application to Partnerships, Gross Receipts and Base-Erosion Percentage Tests, Recharacterization Rules
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax professionals and advisers with a practical guide to the recently issued IRS final regulations on the base erosion and anti-abuse tax (BEAT). The panel will discuss critical provisions of the new IRS final regulations, application to pass-through entities, determining aggregate groups, and Section 6038A reporting requirements. The webinar will also address gross receipts and base-erosion percentage tests, anti-abuse and recharacterization rules, and other crucial considerations.
Outline
- Overview of final and additional proposed regulations
- Critical rules and tests
- Gross receipts and base-erosion percentage tests
- Anti-abuse and recharacterization rules
- Aggregate and consolidated group
- Application to pass-through entities
- Section 6038A reporting requirements and pitfalls to avoid
- Best practices and tax planning opportunities for taxpayers
Benefits
The panel will review these and other key issues:
- Key provisions of the IRS final regulations on the BEAT for taxpayers
- New rules on the application of BEAT to partnerships
- Determining gross receipts and the base-erosion percentage test
- New rules for anti-abuse and recharacterization
- Rules for deciding aggregate and consolidated groups
- Critical Section 6038A reporting challenges and methods to overcome them
- Proposed waiver election
Faculty
Anke Krueger
Managing Director
BDO USA
Ms. Krueger has been a member of the International Tax consulting group for more than 10 years. She consults on both... | Read More
Ms. Krueger has been a member of the International Tax consulting group for more than 10 years. She consults on both inbound and outbound cross-border tax planning for public and privately-held companies.
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Joshua D. Odintz
Partner
Baker McKenzie
Mr. Odintz is the managing partner of the firm's Washington Tax Department. He held high-level government positions... | Read More
Mr. Odintz is the managing partner of the firm's Washington Tax Department. He held high-level government positions with both the U.S. Department of the Treasury and the Senate Finance Committee. He previously served as a Senior Advisor for Tax Reform to the Assistant Secretary at the U.S. Department of the Treasury, where he advised Senior Treasury officials on tax reform options and issues. He also served as the Chief Tax Counsel to the President’s National Commission on Fiscal Responsibility and Reform, and was instrumental in formulating the tax proposals that were contained in the Commission’s report, entitled the Moment of Truth. Additionally, he served as the Acting Tax Legislative Counsel at the Treasury.
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