New Section 59A: Base Erosion and Anti-Abuse Tax (the "BEAT")

Thursday, May 23, 2019  -  Earn 1.5 CE Credits 
Live Webinar United States Time Zones:
1:00 PM – 2:30 PM EDT /  12:00 PM – 1:30 PM CDT  / 10:00 AM – 11:30 AM PD

The Tax Cuts and Jobs Act 2017 imposes an entirely new tax on corporations
with substantial gross annual receipts known as the Base Erosion and
Anti-Abuse Tax or BEAT.  The BEAT is essentially a tax measured by the
amount of deductible payments or accruals to a foreign related party.
Proposed regulations were issued December 13, 2018.  New Form 8991 used to
compute BEAT was released in February of 2019.  Information reporting under
Form 5472 has been expanded. BEAT is generally effective for payments paid
or accrued in tax years of "applicable corporations" beginning after
December 31, 2017.  The intended targets of the BEAT are domestic
subsidiaries and branches of foreign business enterprises but BEAT may also
apply to U.S. owned domestic corporations which make payments to related
foreign persons.

Our instructor will cover from a practical viewpoint the following topics:

-    Determination of Applicable Taxpayer Status including aggregation of
corporations for purposes of $500,000,000 average annual gross receipts test
for preceding three year period and the base erosion percentage.

-    Identification of base erosion payments and tax benefits including
exceptions for payments for services and cost of goods sold.

-    Determination of Modified Taxable Income which begins with taxable
income and "adds back" base erosion tax benefits and the base erosion
percentage of NOL.

-    Determination of Regular Tax Liability with reductions for certain
credits.

-    Calculation of BEAT liability with an illustration.

-    Guided tour of the new Form 8991.

-    Planning strategies for the elimination or minimization of the
impact of BEAT.

Level: Intermediate
Delivery Method: Group-Internet Based Live
Recommended CPE/CLE Credit: 1.5 Credit
Field of Study: Taxes
Prerequisites:  An introductory course on international taxes and a working knowledge of international transactions
Advance Preparations: None
Who Should Attend: This webinar is for CPAs, tax executives, accountants, tax attorneys and financial executives.

Presented By:

William K. Norman is a Partner in the law firm of Ord & Norman in Los Angeles, California and is a Coordinator of its Private Client and International Business Transactions Departments.  He is also a member of the firm’s Tax Litigation and Controversy Group.  He is a Certified Specialist in Taxation Law.  In his practice, he focuses on the counseling of clients in cross border business transactions, cross border real estate investment structures, personal wealth planning for the multinational family, offshore voluntary disclosures, expatriation's of U.S. citizens and green card holders, use of trusts by multinational families, and representation of taxpayers before the IRS and the Tax Court.  Mr. Norman received an A.B. degree in economics from the University of California at Berkeley, a J.D. degree from the University of California and an LL.M. (in taxation) degree from New York University School of Law.  He is a senior adjunct professor in the Graduate School of Taxation, Golden Gate University. He is immediate past chair of STEP-LA Branch.  He has appeared as a speaker and seminar leader at the USC Tax Institute and the New York University Tax Institute.  In June of 2008, the Taxation Section of the Los Angeles County Bar Association presented the Dana Latham Award to him in recognition of his outstanding contributions to the field of taxation. For more information: