The 2017 Tax Cuts and Jobs Act (TCJA) ushered in the most sweeping tax law change in more than three decades, with 86 provisions that modified, added to, or repealed business and international taxes. After three challenging years of implementing the TCJA, the IRS now faces the critical task of administering and ensuring compliance with the law. Informed by lessons learned from TEI members in the CAP program who have undergone IRS examinations of TCJA issues, our panel of leading practitioners will engage in an interactive dialog, covering topics such as, the multiple facets of section 965 transition tax examinations (e.g., reporting requirement compliance, structuring to limit E&P, characterization issues, and compliance recalculations); GILTI high-tax-exemption issues; FDII documentation requirements; select issues involving the base erosion and anti-abuse tax; overview of relevant IRS campaigns; and the interplay of TCJA issues with state and local taxes.
At the conclusion of this course, participants should:
Be aware and have a more informed understanding of the multiple facets of section 965 transition tax examinations;