Exporters seeking to maintain competitiveness must consider IC-DISC structuring, especially as domestic tax incentives and rate regimes shift under the One Big Beautiful Bill.
In the post-OBBBA environment, foreign reporting obligations, cross-border audits, and compliance risk demand greater vigilance.
Cross-border business remains one of the most complex and high-stakes advisory areas. As the One Big Beautiful Bill Act introduces changes affecting corporate tax structures and international flows, transfer pricing is more strategic — and more scrutinized — than ever.
As the federal tax landscape continues to shift under the One Big Beautiful Bill Act and its ripple effects, CPAs face a critical moment: how to balance proactive planning with compliance while strengthening their advisory role.
The IRS and Treasury plan to roll back Disregarded Payment Loss (DPL) and Dual Consolidated Loss (DCL) rules after industry pushback. Learn how these proposed changes could ease compliance burdens, affect international tax planning, and what CPAs and advisors need to know before the October 21, 2025, comment deadline.
The G7 has backed a side-by-side framework that treats U.S. rules like GILTI and NCTI as equivalent under OECD Pillar Two, shielding U.S. companies from foreign top-up taxes. For CPAs, this development simplifies compliance and modeling while underscoring the need to monitor OECD implementation closely.
The One Big Beautiful Bill replaces the FDII deduction with a streamlined Foreign-Derived Deduction-Eligible Income (FDDEI) regime. While the changes simplify compliance and remove certain offsets, they also reduce the deduction rate and expand exclusions, prompting CPAs to revisit export-focused tax planning.
Host Tim LeMasters and guest Jason Rauhe, CPA, dive into the complexities of the new One Big, Beautiful Bill (OB3) and its shifts in US international tax law.
The One Big Beautiful Bill (OBBB) replaces the GILTI regime with Net CFC Tested Income, dramatically changing how U.S. shareholders are taxed on foreign earnings. With the repeal of QBAI and interest deductions, CPAs and multinational businesses must revisit their international tax strategies to avoid surprises under the new rules.
Mexico’s Tax Administration Service (SAT) has dramatically increased Transfer Pricing enforcement, collecting over 106 billion pesos from multinational corporations between 2019 and 2024. With stricter documentation requirements and a specialized audit department, companies must reassess their compliance strategies to avoid costly adjustments.
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Exporters seeking to maintain competitiveness must consider IC-DISC structuring, especially as domestic tax incentives and rate regimes shift under the One Big Beautiful Bill. This session delivers both technical depth and advisory finesse to help CPAs counsel clients on export tax optimization.
Learning Objectives:
By the end of this webinar, attendees will be able to:
-Analyze how OBBB influences export structuring and tax rate arbitrage
-Review IC-DISC mechanics, updated guidance, and audit considerations
-Evaluate opportunities to integrate IC-DISC with other specialty credits
-Apply techniques for positioning IC-DISC strategies to client leadership
-Assess case studies highlighting when IC-DISC is most beneficial
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