Beyond Borders: Navigating H.R. 1's New International Tax Rules

Overview

Get up to speed on the international tax provision overhaul in H.R.?1, P.L. 119-21, commonly referred to as One Big Beautiful Bill Act or OBBBA, in this concise 1-hour session, part of the H.R. 1 Tax Masterclass Series. 

We'll cover:

• Rate adjustments to Sec. 250 (formerly foreign derived intangible income or FDII) and Sec. 951A (formerly global intangible low-taxed income or GILTI) and base erosion and anti-abuse tax (BEAT) rules
• Modifications to the foreign tax credit (FTC) rules under sections 904 and 960, including sourcing inventory sales and haircuts to taxes deemed paid attributable to previously taxed earnings and profits

You'll learn how reinstatement of Sec. 958(b)(4) drastically reduces Form?5471 filings, simplifying compliance related to U.S. shareholder inclusions. 

We'll close with practical planning considerations for cross-border operations and tax-efficient repatriations.

Prerequisites

Fundamental knowledge of the new H.R. 1 tax bill, commonly referred to as OBBBA.

Objectives

• Calculate impacts due to rate adjustments and other international provisions.
• Identify effective tax changes for outbound investment and U.S. multinational planning.
• Identify base erosion payments and structure transactions to minimize BEAT exposure to effectively navigate BEAT.
• Calculate the reduction in Form?5471 filings and streamline U.S. shareholder reporting requirements by leveraging Sec. 958(b)(4) relief.

Highlights

• Rate shifts and other adjustments to Sections 250 and 951A, BEAT, FTC changes
• Reinstatement of Sec. 958(b)(4); the reduction in Form 5471 filings; new Section 951B; and potential increase in application of passive foreign investment company rules