National Tax Conference 2018

NTA1804 - FDII and GILTI…Until Proven Innocent

Nov 12, 2018 10:45am ‐ Nov 12, 2018 12:00pm


This panel will address emerging issues and Treasury Department guidance relating to the new Code sections 250 and 951A (the so-called FDII and GILTI rules).

  • Identify the technical rules and issues under Code sections 250 and 951A
  • Recognize the interaction between those regimes and other Code provisions, including the foreign tax credit rules


  • Ronald Dabrowski, J.D., Principal, KPMG LLP
  • Doug Poms, J.D., Tax Counsel, Office of Tax Policy , US Department of the Treasury
  • Brenda Zent, Special Advisor on International Taxation, Office of Tax Policy, US Department of the Treasury

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