"One, Big, Beautiful Bill"

Please join us for a discussion including topics:

• State of Play
• Current Provisions Extended/Permanent
• Newly Enacted Provisions
• Robust U.S. Tax System Compared to Pillar II
• Next Steps

The Senate Finance Committee’s proposed substitute to “One Big Beautiful Bill Act” (H.R.1) would make key business tax provisions permanent and introduce notable changes to the U.S. international tax regime. These include (i) elimination of Gilti expense apportionment, (ii) new rules for FDII, (iii) Section 899 targeting extraterritorial foreign taxes, (iv) revised BEAT mechanics and (v) sourcing changes under Section 863(b). These updates will reshape how multinationals model investment returns, navigate foreign tax credits, and structure intangible property and intercompany payments.

Learning Objectives:

• Understand the implications of FDDEI, BEAT, and Section 899 for inbound and outbound structures.

• Evaluate the interplay between expense apportionment, sourcing, and the foreign tax credit limitation.

• Identify areas of complexity and uncertainty in the Senate Finance bill affecting future structuring decisions.

Discussion:

Pat Brown, PwC

Danielle Rolfes, KPMG

CLE/CPE will not be offered for this virtual event.