Overview of the changes to the taxation of international tax activities under the Tax Cuts and Jobs Act. The course will include a discussion of the shift to territorial system of taxation, transition tax or mandatory deemed repatriation, Global Intangible Low Tax Income (GILTI), Foreign Derived Intangible Income (FDII), Base Erosion Anti-Avoidance Tax (BEAT), and other miscellaneous provisions impacting the taxation of international activities.
Identify taxpayers that will be impacted by the transition tax under Section 965.
Understand what Global Intangible Low Tax Income is and how it is taxed.
Understand what Foreign Derived Intangible Income is and how it is taxed.
Identify which taxpayers are impacted by the new Base Erosion Anti-Avoidance Tax.
Understand several of the miscellaneous provisions that impact the taxation of International activities.
Chaya is the Lead of Withum’s International Business Tax with more than ten years of professional experience, including public accounting and private industry. She has expertise in advising U.S. and foreign multinational companies on their international operations’ tax implications and coordinating U.S. tax laws with foreign tax laws to develop an optimal worldwide tax strategy.
Chaya is fluent in the rules and regulations regarding controlled foreign corporations, PFICs, withholding taxes, income tax treaty analysis, check-the-box planning, FIRPTA, and foreign informational reporting forms. She is responsible for a variety of assignments with domestic and international companies, including tax due diligence, tax compliance, tax provision, and uncertain tax positions; global tax minimization planning; subpart F analysis and computation; foreign tax credit studies; earnings and profit studies; acquisitions and dispositions of operating units; and other related matters.
She formerly worked for PwC and global hedge fund Caxton Associates.
Chaya is a licensed CPA in the State of New York. She received her MST degree in Taxation from Golden Gate University and her Bachelor of Science degree in Business Administration from the State University of New York.