New Proposed PTEP Regulations: Maintaining Shareholder Accounts, Tracking Basis Adjustments, Implementation
Recording of a 110-minute CPE webinar with Q&A
This webinar will review the key components of the new proposed PTEP (previously taxed earnings and profits) regulations for CFCs, international shareholders, and multinational entities. Our panel of astute international tax experts will address the updates made to Sections 959 and 961 and point out the issues the new regulations will resolve as well as those that are still problematic. They will recommend steps international practitioners need to take immediately to prepare for these modifications to the U.S. foreign taxation regime.
Outline
- Introduction
- PTEP accounting
- Shareholder accounts
- Basis adjustments
- Ordering rules
- Partnership rules
- Consolidated return rules
- Foreign currency provisions
- Other components
- Effective date
- Implementation
Benefits
The panel will cover these and other critical issues:
- Complying with shareholder account maintenance provisions under the proposed PTEP regulations
- Calculating lower-tier basis under the new regulations
- Steps multinational entities and their advisers should take to prepare for foreign regulation changes
- Key issues not addressed in the proposed PTEP regulations
Faculty
Cynthia Furmanek
Senior Manager
PwC
Ms. Furmanek is a senior manager in the International Tax Services practice at PwC’s Silicon Valley office.... | Read More
Ms. Furmanek is a senior manager in the International Tax Services practice at PwC’s Silicon Valley office. She advises multinational clients—primarily in the software and technology industry—on structuring global operations, foreign tax planning, cross-border acquisitions and reorganizations, and repatriation strategies. An attorney with experience in international tax since 2014, Ms. Furmanek specializes in managing foreign tax attributes, including foreign tax credits and earnings and profits. She combines her legal and tax expertise to help clients navigate complex cross-border tax considerations. Ms. Furmanek has written on international tax topics, including a recent article published in Tax Analysts.
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Kodj Gbegnon
Principal
PwC
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San... | Read More
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San Jose). His practice focuses on tax planning for cross-border M&A and restructurings, IP integration, taxation of online / digital transactions and tax attribute planning (including foreign tax credits). Mr. Gbegnon is a member of the California Bar Association.
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David Sotos
Principal
PwC
Mr. Sotos is principal and a member of PwC’s Washington National Tax practice, based in San Jose. His... | Read More
Mr. Sotos is principal and a member of PwC’s Washington National Tax practice, based in San Jose. His practice involves advising clients and PwC practice teams on a wide array of outbound and inbound international tax matters, including cross-border M&A, IP integration, foreign tax credits, dual consolidated losses, anti-deferral, and US tax treaties.
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