New Section 59A: Base Erosion and Anti-Abuse Tax (the "BEAT") 2019 | Networking Seminars Inc. | 23 May 2019 |

The BEAT presents challenges for common business structures used by both non-U.S. based and U.S.-based multinationals. Non-U.S. corporations with income effectively connected to a U.S. trade or business and related party payments may be subject to the BEAT, requiring a careful analysis of the new tax rules.

The impact of new §59A on non-U.S. Based and U.S.-based multinationals

• Analyzing the reporting requirements and exemptions of the BEAT
• Identifying transactions that may be subject to the BEAT
• Determining modified taxable income subject to §59A
• Tax rate application and methods of calculating the BEAT
• Tax planning tips limiting exposure and reducing taxable income subject to the anti-abuse tax

The BEAT targets U.S. tax-base erosion by imposing an additional tax liability on certain corporations that make payments to related foreign persons by adding back to taxable income certain deductible payments made to such foreign persons. The BEAT amounts to an alternative minimum tax on a taxpayer’s taxable income regardless of the tax benefits arising from the payments to foreign persons. This modified taxable income is subject to a tax rate of 5% starting from the 2018 tax year and increasing to 12.5% beginning in 2025. Key topics include:

• Determine the applicability of §59A to U.S. based corporations and non-U.S. affiliates
• Methods in calculating modified taxable income and applicable tax rates
• Identifying transactions or operations subject to the BEAT
• The impact of net operating losses in determining modified taxable income
• Recognizing the interaction of BEAT with other new tax law provisions

2019 Speakers

Bill Amon
Managing Director at Anderson Tax

John Apuzzo
International Tax Senior Director located in the Los Angeles office of PricewaterhouseCoopers LLP

Sherif Assef
Principal at KPMG LLP

Andrew Bernard
Managing Director at Andersen Tax in Philadelphia

Rivi Biton
International Tax Specialist in International Tax Quantitative Services

Trevor Blumenfeld
Manager at the KPMG LLP

Devon M. Bodoh
Principal in KPMG’s Washington National Tax Corporate

Christopher Booth
Director in the International Tax Service Line with Deloitte

Anne Bouse
Senior Manager at Ernst & Young LLP

Howard Braithwaite
Director in KPMG’s Philadelphia International Tax practice

Margaret Brown
Member of Ernst & Young’s

Greg Bryant
Lawyer and certified public accountant

Oscar Burakoff
Principal economist in DLA Piper's Tax practice

Kevin Burke
Principal in Ernst & Young’s International Tax Services group in Boston

Sarah Busker
Executive Director in Ernst & Young’s Houston office

Amy Cannefax
Sr. Manager in the Federal Tax Practice at KPMG LLP

Rui Che
Senior Manager in the Philadelphia office of KPMG LLP’s

Chuck Chubb
Managing Director at Anderson Tax

Robert A. Clary II
Partner in the law firm of McDermott Will & Emery LLP

Jason R. Connery
Principal at KPMG LLP

Brendan Cox
Partner at Ernst & Young LLP

John Crucs
Managing director in the International Tax group at KPMG LLP

Paul Dau
Counsel in the law firm of McDermott Will & Emery LLP

Steven M. Davis
Principal in the International Tax Services group at KPMG LLP’s

Ghansham Dhanak
Director in the International Tax Services practice

Greg W. Featherman
Senior Manager in KPMG’s Washington National Tax Corporate practice

Andrew R. Fisher
Director in Deloitte Tax LLP’s U.S

Paul Flignor
Principal Economist with DLA Piper's Tax group

Stephen C. Fox, CPA
Co-author of "Passive Foreign Investment Company Rules are Complex and Unforgiving" in Journal of Taxation of Investments

Maureen Garcia
Member of Ernst & Young LLP’s International Tax Services

Victor Gatti
Principal with KPMG’s New York Financial Services Practice

Christine Groen
Senior Associate in Grant Thornton LLP’s Melville office

Joel Gross
Senior manager in KPMG’s International Tax practice

Alexander Hanhan
Tax Managing Director with the International Corporate Services

Mike Hardgrove
Partner in DLA Piper's Tax practice

Gwendolyn L. Hulsey
Member of the Tax Practice Group at Baker & McKenzie LLP

Jessica Joy
Duff & Phelps in 2012

Vinay Kapoor
Principal in KPMG’s Economic and Valuation Services practice

Kathrine Kimball
Principal of Deloitte Tax LLP

Neal Kochman
Member of Chaplin & Drysdale

Nelly Korsun
Director in the New York office

Jaclyn Obeso Kunkel
Manager in KPMG’s Philadelphia International Tax practice

Frank Landreneau
Director of International Tax Services at Pannell Kerr Forster of Texas

Elizabeth Lieb
Corporate and international tax planning at Baker & McKenzie in Palo Alto

Erin Lien
Member of Ernst & Young LLP’s

Mike Lutz
Partner at Ernst & Young LLP

Neelu Mehrotra
Member of Ernst & Young LLP’s

Sean K. McFerson
Partner at Windes LLP

Robert J. Misey, Jr.
Shareholder at Reinhart Boerner Van Deuren

Evgeniya Mudrich
Manager in KPMG’s New York Financial Services Tax practice

Reza Nader
Member of Baker & McKenzie’s

Zey Nasser
Member of Ernst & Young LLP’s International Tax Services practice

Maruti Narayan
Counsel in the New York office of DLA Piper LLP

William K. Norman
Partner in the law firm of Ord & Norman

Ben Olivas
Partner in the International Tax group at DLA Piper

Melinda R. Phelan
Member of the management committee for Baker & McKenzie's North America Tax Group

Peter J. Scalise
Federal Tax Credits & Incentives Practice Leader for the Americas at Prager Metis CPAs, LLC

Caren S. Shein
Managing Director at KPMG LLP’s

Moshe Spinowitz
Represents clients

Paul Tadros
President at DSN Consultants

Jay Tata
KPMG’s International Corporate Services tax practice

Gabriel Taubenfeld
Senior Manager in Ernst & Young LLP’sInternational Tax Services practice

Brian Trauman
Partner and tax lawyer at KPMG LLP

Eric Tyan
International tax senior manager at KPMG LLP

Miquel (Mike) Valdes
Specializes in Latin America and Caribbean

Nelson Valentine
Currently a senior manager at Deloitte Tax LLP

Theodor van Stephoudt
Economist with SNR Denton

Steve Weerts
Partner in the Tax practice of White & Case

John T. Woodruff
Partner in the law firm of McDermott Will & Emery LLP

Steven C. Wrappe
Principal in KPMG’s Economic and Valuation Services practice

Katherine (Kathy) Wu
Executive Director with Ernst & Young LLP’s

Raymond Wyeth
Partner at Grant Thornton

Raymond P. Wynman
Director of Global Tax Management’s International Tax practice

David Young
Senior Manager in the International Corporate Services tax practice

Mark Young
Managing Director with Alvarez & Marsal Taxand, LLC

Thomas H. Young
Partner in the law firm of McDermott Will & Emery LLP

Janette Zive
Partner with the International Tax Services team at PricewaterhouseCoopers LLP

Joanna Zong
Tax senior manager in KPMG’s New York Financial Services

2019 Sponsors

• Baker McKenzie
• Deloitte
• Ernst & Young
• KMPG
• Pwc
• Andersen Tax
• DLA Piper
• McDermott Will & Emery
• Skadden
• Bilt Group
• Grant Thornton
• LataxNet