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REMOTE PROGRAM: A Discussion on the International Tax Provisions of the One Big Beautiful Bill Act
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Credit: 0 CLE Credit Hours
Join the D.C. Bar Taxation Community for a panel discussion on some of the cross-border and international tax provisions in the recently enacted One Big Beautiful Bill Act. The OBBBA modified some of the U.S. international tax provisions enacted under the 2017 Tax Cuts and Jobs Act (TCJA), including changes converting global intangible low-taxed income (GILTI) to net CFC tested income (NCTI) and foreign-derived intangible income (FDII) to foreign derived deduction eligible income (FDDEI). The OBBBA includes other international tax changes, including expense allocation and income sourcing rules under the foreign tax credit regime, repeal of the one-month deferral for specified foreign corporations, re-enactment of the pre-TCJA limitation on ownership attribution rules for CFC determination purposes, creation of a new foreign CFC regime for certain controlled corporate ownership groups, and modifications to the pro rata share rules for determining a U.S. shareholder’s subpart F and NCTI inclusions. Panelists will discuss the implications of the OBBBA international tax provisions on multinational clients and Treasury and IRS guidance plans for implementation.
Pre-registration is required. As always, please feel free to share this invitation with colleagues. D.C. Bar membership is not required to attend. Non-members will need to create a profile to register.
If you would like to attend this program in-person, please click here for that registration page.
Renew or join Communities to receive the best discount on registration. Click here to log in and join Communities.
Are you a current law student and looking to register for one of our programs? Learn about the D.C. Bar Law Student Community and attend most individual programs at a discounted rate. Find out more here.
This remote program will be hosted on the Zoom platform. You will receive access information from D.C. Bar Communities staff the afternoon prior to the program. The Zoom access information should not be shared with others, as individual registration is required.
Sponsored by: D.C. Bar Taxation Community
Related Communities of Interest: D.C. Bar Corporation, Finance and Securities Law Community; D.C. Bar Early Career Lawyers Community; D.C. Bar Estates, Trusts and Probate Law Community, D.C. Bar International Law Community; D.C. Bar Law Student Community
Speakers:- Jonathan Galin, Attorney Advisor, Office of Tax Policy, U.S. Department of the Treasury (Invited)
- Quyen Huynh, Principal, KPMG LLP
- Huzefa Mun, Attorney Advisor, Office of Tax Policy, U.S. Department of the Treasury (Invited)
- Caroline Ngo, Partner, McDermott Will & Schulte LLP
- Joshua Ruland, Principal, Ernst & Young LLP
- Tracy Villecco, Senior Technical Reviewer, Associate Chief Counsel (International), Internal Revenue Service (Invited)
- Scott Levine, Partner, Baker & McKenzie LLP (Moderator)
**Early bird registration ends Friday, September 19th.
Early Bird rate expires Friday, September 19, 2025 | Registration Fees | Early Registration | Standard |
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| Non-Member | $30.00 | $40.00 | | D.C. Bar Member | $20.00 | $30.00 | | D.C. Bar Premium Community Member | $0.00 | $0.00 | | D.C. Bar Regular Community Member | $0.00 | $0.00 | | Law Student Community | $0.00 | $0.00 |
| Government Registration Fee | Early Registration | Standard |
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| Non-Member | $15.00 | $20.00 |
| Non Profit Registration Fee | Early Registration | Standard |
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| Non-Member | $15.00 | $20.00 |
| Law Student Non Member Registration | Early Registration | Standard |
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| Non-Member | $0.00 | $10.00 |
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