Überblick
McDermott partners Steven Hadjilogiou, Sandra McGill, Alysse McLoughlin and associate Kathleen Quinn will be speaking at the Florida Institute of Certified Public Accountants‘ (FICPA) 37th annual International Tax Conference, hosted in Miami on January 9-11, 2019.
With the amendments to the Tax Cuts and Jobs Act and subsequent regulatory changes, this conference offers those who practice in the area of international taxation—whether your inbound, outbound or both, corporate or public practice—this conference provides the opportunity to learn from experts and develop your existing understanding.
Steven Hadjilogiou and Sandra McGill will lead a session entitled ‚GILTI vs. FDII: The Epic Showdown‘ on January 10, 2019 at 10:40-11:30am. The session examines how the Tax Cuts and Jobs Act introduced two corollary provisions into the tax code. One provision (FDII) was designed to provide a benefit to corporations that create jobs and retain assets, especially intellectual property, in the United States. The other provision (GILTI) was designed to punitively tax American owned foreign corporations that own intellectual property that generates low-taxed foreign income. The speakers will review the similarities and differences between these provisions and discuss the benefits and burdens of both provisions. Finally, the presentation will look at structuring options that may be considered by taxpayers faced with the punitive GILTI regime and taxpayers seeking to obtain the benefits of the FDII regime.
Alysse McLoughlin and Kathleen Quinn will lead a session on ‚The Intersection of International and SALT‘ on January 10, 2019 at 10:40-11:30am. This presentation will focus on the state tax treatment of the international provisions of the Tax Cuts and Jobs Act, the federal tax reform bill passed in December 2017. We will also discuss the Supreme Court’s decision in South Dakota v. Wayfair and the impact of that decision on non-US persons and businesses.
Read more on FICPA’s 37th annual International Tax Conference here.