National Tax Conference 2018

NTA1808 - BEAT (but not GILTI!): Other Changes to the Subpart F Rules

Nov 12, 2018 1:00pm ‐ Nov 12, 2018 2:15pm


This session will cover the operation of and issues related to the new Base Erosion and Anti-abuse Tax as well as how the expansion of the rules relating to Subpart F (excluding the new GILTI provision) impact taxpayers, including the repeal of section 958(b)(4).

At the end of this session you should:

  • Recognize who is an “applicable taxpayer” for purposes of determining who is subject to the BEAT
  • Know when there is a “base erosion payment” and how the BEAT is calculated
  • Appreciate the implications of the changes to the rules relating to Subpart F on various transactions and structures


  • Joseph Calianno, CPA, J.D., LL.M. (Taxation), Partner & International Technical Tax Practice Leader, BDO
  • 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
  • Michael Miller, J.D., Partner, Roberts & Holland LLP

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