M07 - Planning for the Proposed Shift to Per-Country Application of GILTI and FTC Limitations

Description

This session will discuss how multinational enterprises should prepare to address the potential implementation of a per-country limit on foreign tax credits and GILTI. Both changes present planning opportunities and risks, as well as significant compliance issues.

Learning Objectives:

• Understand the implications of per-country limits on the FTC and GILITI
• Assess what advance planning opportunities and risks are or might be available to their company
• Determine the compliance issues associated with FTC and GILTI limits with the greatest impact on their company.

Moderator(s):

• Mr. Peter Waterstreet, Senior Director, International Tax, VMware, Inc.

Speaker(s):

• Mr. J. Brian Davis, BakerHostetler LLP
• Mr. Stephen R. Bates, Principal - National Tax - International Tax & Transaction Services, Ernst & Young LLP
• Mr. Reed Kirschling, Deloitte Tax LLP