This session, from TEI’s 2025 Federal Tax Course – Level 1, covers key aspects of U.S. international taxation, including updates on the Global Intangible Low-Taxed Income (GILTI), Foreign-Derived Intangible Income (FDII), and Base Erosion and Anti-abuse Tax (BEAT) regimes established by the Tax Cuts and Jobs Act, along with other anti-base erosion provisions. Additional topics include the income sourcing rules, the basics of controlled foreign corporations (CFCs) and the treatment of the sale of CFC stock, transfer pricing, Subpart F income, Previously Taxed Earnings and Profits (PTEP), foreign tax credits, and income tax treaties. The session is designed to help professionals navigate complex global tax issues and optimize cross-border tax strategies.
Learning Outcomes
- Understand the basics of U.S. international tax, including CFCs, choice of entity considerations, Subpart F, PTEP, and the sourcing rules
- Explore the impact of the post-TCJA anti-deferral regime and the interplay of the U.S. international tax provisions that affect U.S. tax
- Explore transfer pricing methods and gain insight into compliance requirements and potential dispute resolution options
Who Should Attend
This course is designed for tax professionals who are new to the in-house community, taking on new areas of responsibility, changing areas of practice, or just need a refresher on the core principles in US federal taxation.
Instructor(s)
Jayshree Narendran, Associate, Baker McKenzie LLP
Amir-Kia Waxman, Partner, Baker McKenzie LLP
Sahar Zomorodi, Partner, Baker McKenzie LLP
General Session Information
Access
Online, upon completion of the checkout process, you will be directed to our Learning Management System (LMS) for access to the session
For member pricing, please login to tei.org
This is a digital product. With full paid access the content will be available for one year after the purchase date
CPE Credits
This digital product is not eligible for Continuing Professional Education (CPE) credit and includes the recording from the 2025 in-person session and the corresponding PowerPoint slides
Length of Session
The session will take approximately 3.5 hours to complete
NASBA Field of Study
Taxes
Level
Basic
Prerequisites
None
For more information, please refer to CPE requirements and NASBA sponsorship information
Terms & Conditions
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