17 September 2020

Thursday, 24 September 2020 | BorderCrossings... With EY transfer pricing and tax professionals - Foreign-derived intangible income (FDII) final regulations (1 pm ET)

Foreign-derived intangible income (FDII) final regulations

The Treasury and IRS recently finalized regulations under Internal Revenue Code Section 250, covering the tax benefits available in the FDII provisions added by the Tax Cuts and Jobs Act (TCJA). Join us as we discuss the FDII deduction and associated issues to consider, with a focus on operating model and transfer pricing interactions.

We will cover:

  • FDII background, definitions and calculations
  • Key modifications and clarifications in the final regulations
  • A review of key considerations with respect to the FDII deduction, including potentially reducing negative effects and increasing FDII benefits, with coverage of:
    • Computational considerations
    • Transfer pricing range and methods
    • Qualified business asset investment
    • Operating model implications and approaches in relation to services, sales and manufacturing, as well as intellectual property

We hope you join us for this important webcast.

Date: Thursday, 24 September 2020

Time: 1:00-2:15 p.m. EDT New York/Toronto; 10:00-11:15 a.m. PDT Los Angeles/Vancouver

Registration: Register for this event.

Panelists

  • Michael J. Bowes, EY Americas Operating Model Effectiveness Leader, International Tax and Transaction Services
  • Jay Camillo, EY Global Operating Model Effectiveness Leader, International Tax and Transaction Services
  • Bryant Jiravisitcul, Senior Manager, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP
  • Ryan J. Kelly, Principal, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP
  • Daniel Sosna, Managing Director, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP

Moderator

Mike McDonald, Managing Director, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP 

CPE credit offered: 1.5. Recommended field of study: Taxes. See CPE FAQ for more information.

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Document ID: 2020-6232