The program will highlight the expanded surtax on certain foreign payments, the interaction of OBBBA provisions with the Base-Erosion and Anti-Abuse Tax (BEAT), and the compliance impact on U.S. companies with foreign shareholders. Attendees will learn how these reforms alter planning for corporations, partnerships, trusts, and exempt organizations with international exposure.
Learning Objectives
- Learning Outcomes
- Identify how OBBBA expands surtaxes on U.S. payments to foreign recipients
- Recognize the elimination of gross receipts and base erosion thresholds under prior law
- Apply the revised rules to U.S. corporations with majority foreign ownership
- Determine when the Majority U.S. Owner Exception applies
- Assess how partnerships, trusts, and private foundations are impacted by new surtax provisions
- Evaluate planning considerations under the modified BEAT framework
- Assess and prepare to advise clients on compliance and reporting obligations created by the new law
- Identify risks and opportunities for U.S. multinationals and investment funds
