12:00-1:15 PM ET

Program:
This webinar will cover the transactional aspect of the GloBE rules, in particular those rules contained in Articles 4.4 (deferred tax adjustments), 6 (corporate restructurings) and 9 (transition rules). The webinar will focus on the application of GloBE in the context of deemed asset sales (e.g. U.S. section 338 and 754 elections), the different treatment of asset transfers under US GAAP versus IFRS, the impact of purchase price accounting and push down accounting adjustments on GloBE calculations, the treatment under GloBE of deferred tax assets and liabilities that arise from acquisitions and internal asset transfers, and the application of the special transition rules in articles 9.1.2 and 9.1.3 as they relate to transactions undertaken before GloBE comes into effect. The panelists will discuss how the recently issued Administrative Guidance changes the analysis of these issues.

Learning objectives:

• Understand the application of GloBE to U.S. deemed asset sales
• Understand the application of the special Article 9 transition rules
• Understand the relevance of purchase price and push down accounting adjustments to GloBE

Moderator:
Jason Yen, Principal, EY

Panelists:
Jeff Mitchell, Senior Advisor, Working Party 11, OECD  
James Petrie, Partner, Deloitte
Gary Scanlon, Principal, KPMG
Brenda Zent, Special Advisor on International Taxation, U.S. Department of the Treasury

Registration:

Webinar are free for IFA USA members.
Non member rate: $100

Please note that the registration process will be in two steps. First, purchase your pass on our website by clicking the Register button above. After you complete your registration, you will receive an invitation from the Zoom platform where you will need to complete your registration for the live virtual event.

Scholarship Information
Cancelation and Refund Policy

CLE/CPE Information

Recommended CLE credits: 1.5 Taxation
Recommended CPE credits: 1.5 Taxes
In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour. IFA USA National Registry Sponsor # 112000
Program Level: Basic-CPE, Intermediate-CLE
Program prerequisites: None
Advanced Preparation: None

USA Branch, International Fiscal Association Inc. (IFA USA) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org

National Registry Sponsor #112000