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Robert Russell Participated In The Panel Entitled “Outbound Tax Developments,” At The Federal Bar Association’s 2020 Tax Law Conference

The TCJA made significant changes to how income of controlled foreign corporations is taxed. The operation of the new Global Intangible Low-Taxed Income (GILTI) continues to be molded as guidance is released related to foreign tax credits, previously taxed earnings and profits and foreign-derived intangible income.

Topics discussed:
• Guidance related to foreign tax credit.
• Address the current status of previously taxed earnings & profits (PTEP).
• Explore the impact of the foreign-derived intangible income (FDII) provision and accompanying regulations.

Brandon King, Associate, Baker & McKenzie LLP (moderator)
John Bates, Principal, Deloitte Tax LLP
Robert Russell, Counsel, Kostelanetz & Fink, LLP
Jeffrey L. Parry, Senior Counsel, I.R.S. Office of Chief Counsel(INTL)
James Wang, Attorney-Advisor, U.S. Department of the Treasury
Jason Yen, Attorney-Advisor, U.S. Department of the Treasury

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