Forte International Tax, 1603 Orrington Avenue Suite 600, Evanston, IL (2026)

11/14/2025

Join FORTE for an in-depth webinar featuring a comprehensive OB3 Modeling Case Study. This webinar will provide a detailed analysis of OB3’s international tax provisions, illustrating their practical application through examples and highlighting the interplay of the US International Tax calculations under the new law. Expect actionable insights and expert guidance to help you navigate these significant changes with confidence. The VantagePoint™ new OB3 release will be announced.

Learning Objectives
1. Explain the changes to Section 951A and its metamorphosis from GILTI to Net CFC Tested Income (“NCTI”)
2. Analyze the enhancements to Section 250 and the deduction for Foreign Derived Deduction Eligible Income (FDDEI) with a discussion of properly allocated deductions.
3. Explain new rules for generating foreign source income on sales of inventory property through a foreign branch.
4. Evaluate the new Section 174A deduction options and the interplay between R&E, Section 163(j), and the Foreign Tax Credit.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: 1.0 Pending
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Register:
https://lnkd.in/e93cRNSE

03/25/2024

Earn up to 6 CPE this week!

The Global Tax Optimization Bootcamp with Forte International Tax, LLC, FORVIS, Baker Tilly US and McDermott Will & Emery transforms the latest international tax requirements into practical ready-to-use implementation guidance, by combining detailed international tax technical analysis with an integrated Case Study.

Legal structures and entity classifications, transfer pricing, historical tax attributes, tax elections, and Treas. Reg. 1.861-8 methodology all matter and impact your results. They all must be modeled together to ensure data integrity, facilitating global tax optimization. For example, Pillar Two QDMTTs impact the US GILTI and FTC calculations, which then impact Pillar Two Final top-up taxes.

𝐑𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 & 𝐏𝐫𝐨𝐠𝐫𝐚𝐦 𝐈𝐧𝐟𝐨𝐫𝐦𝐚𝐭𝐢𝐨𝐧 𝐏𝐚𝐠𝐞:
https://lnkd.in/dbzU6PqX

𝐌𝐨𝐝𝐮𝐥𝐞𝐬:

Module I - Pillar Two and U.S. Tax Interplay

Module II - Subpart F, GILTI and High-Tax Income Elections

Module III - Treas. Reg. 1.861-8, FDII and Foreign Tax Credit

Module IV - 163(j), BEAT and CAMT

𝐏𝐚𝐧𝐞𝐥𝐢𝐬𝐭𝐬:
Forte International Tax, LLC
Mark Gasbarra
David Merrick
Wendy McDonald

FORVIS
David Macall

Baker Tilly US
Alexis Bergman, JD, LLM, CPA

McDermott Will & Emery
John Karasek

01/03/2024

Join Forte International Tax, LLC and McDermott Will & Emery, for our upcoming complimentary webinar, 𝐆𝐥𝐨𝐁𝐄 𝐌𝐞𝐞𝐭𝐬 𝐆𝐈𝐋𝐓𝐈 - 𝐑𝐞𝐚𝐝𝐲, 𝐒𝐞𝐭, 𝐆𝐨!, Thursday, Jan 11th @ 10:00 AM - 11:00 AM CST.

This session covers IRS Notice 2023-80 including specific rules for the calculation interplay between Pillar Two and GILTI.

A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.

𝐋𝐞𝐚𝐫𝐧𝐢𝐧𝐠 𝐎𝐛𝐣𝐞𝐜𝐭𝐢𝐯𝐞𝐬:
- Understanding how Pillar Two Qualified Domestic Top-up Taxes (QDMTT) impact the calculation of GILTI, including its impact on the GILTI High-Tax Exclusion.
- Understanding how QDMTTs impact the Subpart F High-tax Exception.
- Understanding the definition of a Final Top-up Tax and the U.S. effect on members within and without the MNE Group.
- Understanding the interaction between the U.S. Dual Consolidated Loss Rules with the GloBE Rules.
- Understanding the Extension and Modification of Temporary Relief of the 2002 Foreign Tax Credit Regulations.

𝐏𝐫𝐨𝐠𝐫𝐚𝐦 𝐅𝐢𝐞𝐥𝐝 𝐨𝐟 𝐒𝐭𝐮𝐝𝐲: Taxes
𝐏𝐫𝐨𝐠𝐫𝐚𝐦 𝐋𝐞𝐯𝐞𝐥: Intermediate
# 𝐨𝐟 𝐂𝐏𝐄 𝐜𝐫𝐞𝐝𝐢𝐭𝐬: One (1)
𝐀𝐝𝐯𝐚𝐧𝐜𝐞𝐝 𝐏𝐫𝐞𝐩𝐚𝐫𝐚𝐭𝐢𝐨𝐧: None
𝐏𝐫𝐞𝐫𝐞𝐪𝐮𝐢𝐬𝐢𝐭𝐞: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

𝐑𝐞𝐟𝐮𝐧𝐝𝐬: Due to this program being offered free of charge, there will be no refunds issued.

𝐑𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 & 𝐏𝐫𝐨𝐠𝐫𝐚𝐦 𝐈𝐧𝐟𝐨𝐫𝐦𝐚𝐭𝐢𝐨𝐧 𝐏𝐚𝐠𝐞:
https://lnkd.in/g8ytsxDN

07/27/2023

Please join Forte International Tax, LLC Tuesday, August 1st @ 2 PM CDT for a complimentary webinar and third installment of our Preparing for Pillar Two Series, "New Pillar Two Updates – Final GloBE Information Return (GIR)".

𝐃𝐢𝐬𝐜𝐮𝐬𝐬𝐢𝐨𝐧 𝐓𝐨𝐩𝐢𝐜𝐬:
This session covers OECD Guidance including the following two OECD documents published as of July 13, 2023:
• https://lnkd.in/esABhCeU
• https://lnkd.in/ehhcdpR7

𝐋𝐞𝐚𝐫𝐧𝐢𝐧𝐠 𝐎𝐛𝐣𝐞𝐜𝐭𝐢𝐯𝐞𝐬:
• Understanding the new Qualified Domestic Top-Up Tax (QDMTT) Safe Harbour
• Understanding the Transitional UTPR Safe Harbour for Jurisdictions subject to a Tax Rate of at least twenty percent
• Understanding the new guidance on tax credits including transferable credits
• Understanding the final changes to the GloBE Information Return (GIR)

A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.

𝐏𝐫𝐨𝐠𝐫𝐚𝐦 𝐅𝐢𝐞𝐥𝐝 𝐨𝐟 𝐒𝐭𝐮𝐝𝐲: Taxes
𝐏𝐫𝐨𝐠𝐫𝐚𝐦 𝐋𝐞𝐯𝐞𝐥: Intermediate
# 𝐨𝐟 𝐂𝐏𝐄 𝐜𝐫𝐞𝐝𝐢𝐭𝐬: One (1)

𝐑𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 𝐋𝐢𝐧𝐤:
https://lnkd.in/g_yEqCwx

06/05/2023

Please join Forte International Tax, LLC Monday, June 12th @ 2 PM CST for a complimentary webinar, "Understanding Pillar Two Calculations and the GloBE Information Return".

𝐃𝐢𝐬𝐜𝐮𝐬𝐬𝐢𝐨𝐧 𝐓𝐨𝐩𝐢𝐜𝐬:

This session provides practical guidance on what you need to know in order to effectively prepare for the Pillar Two Global Minimum Tax (GMT). The session outlines the specific operational rules necessary to calculate GMT related Top-Up Taxes as well as the Transitional CbCR Safe-Harbour determinations. The components of the GloBE Information Return (GIR) are explained, including the specific data points necessary for tax administrations to evaluate the correctness of a Constituent Entity’s (CE) GloBE tax liability. A brief Case Study is presented to reinforce the calculation methodology including the interplay of Pillar Two with the GILTI tax calculations.

𝐋𝐞𝐚𝐫𝐧𝐢𝐧𝐠 𝐎𝐛𝐣𝐞𝐜𝐭𝐢𝐯𝐞𝐬:
- Participants will learn the specific operational rules required to calculate potential Top-Up taxes under Pillar Two.
- Participants will understand the differences between the Pillar Two computations and those provided under the Transitional CbCR Safe Harbor provisions.
- Participants will understand how the Pillar Two computational determinations are presented in the GloBE Information Return (GIR).

𝐏𝐫𝐨𝐠𝐫𝐚𝐦 𝐅𝐢𝐞𝐥𝐝 𝐨𝐟 𝐒𝐭𝐮𝐝𝐲: Taxes
𝐏𝐫𝐨𝐠𝐫𝐚𝐦 𝐋𝐞𝐯𝐞𝐥: Intermediate
# 𝐨𝐟 𝐂𝐏𝐄 𝐜𝐫𝐞𝐝𝐢𝐭𝐬: One (1)

𝐑𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 𝐋𝐢𝐧𝐤:
https://lnkd.in/gEzmaqz3

03/19/2023

Please join Forte International Tax at the 73rd Tax Executives Institute Midyear Conference March 19th-22nd in Washington D.C., where will be presenting "Gathering, Wrangling and Utilizing Foreign Entity Data: How Mature Is Your Process?".

For more information please visit: https://23my.tei.org/23my/

We hope to see you there!

02/28/2023

Join Forte International Tax, FORVIS & Baker Tilly as we enter Week Two of our International Tax Boot Camp | LIVE Online Workshop and earn up to 16 CPE.

Register:
https://lnkd.in/gXd6NCH4

12/06/2022

Please join Forte International Tax, LLC, our complimentary webinar, “VantagePoint Demonstration – Integrated Modeling incl GILTI, FDII, FTC and a look at Pillar Two”, this Friday, December 9th @ 10am CST.

Are you looking for a nimble solution with more control to perform your international tax planning and calculations? VantagePoint is the only fully integrated FTC/GILTI/FDII application supporting planning, provision, and compliance requirements. The software is constantly updated with the latest regulations and is multi-year, simplifying amending returns and historical tax attribute tracking.

We are pleased to invite you to this specially scheduled interactive forum, where you can take a closer look at our VanatgePoint™ Global Tax Software to see if it would benefit your Company as a consulting tool or software license.

We work with clients on a consulting, co-sourcing and license basis and want to support you in providing value to your Company in both process efficiencies and tax savings. We work with large multinational firms (Fortune 100+) from a range of industries and simple to very complex tax structures.

We look forward to seeing you there.

Registration:
https://register.gotowebinar.com/register/4717957542911686672

09/13/2022

Please join Forte International Tax, LLC for our upcoming complimentary webinar, “GloBE Meets GILTI - Pillar Two Update”, Wednesday, October 19th @ 2pm CT.

Listed below is an overview of the topics discussed in this webinar.

A – Latest OECD Guidance and Timeline
B – European Union Perspectives – Pillar II and DSTs
C – USA Landscape
D - Practical Modeling Solutions

Learning Objectives
1. The participants will understand the latest OECD Pillar II Guidance including the revised implementation timeline.
2. The participants will understand the status of the EU’s acceptance of Pillar II as well as various DSTs.
3. The participants will understand how various USA international tax rules interplay with Pillar II and gain practical insights on potential modeling scenarios.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

Register Link:
http://register.createasocialcard.top/7kn5p7

08/19/2022

Please join Forte International Tax, LLC our upcoming webinar, “Foreign Tax Credit Regulations (incl. IRS Corrections) Plus: New Book Minimum Tax AMT FTC”, Wednesday, August 31st @ 2pm CT.

Learning Objectives:

1. The participants will understand the specific requirements, as prescribed by the latest updates to the foreign tax credit regulations, in order to be able to obtain a foreign tax credit for foreign taxes paid or accrued.
2. The participants will understand the rules for allocating and apportioning foreign income taxes between the various operative sections of the internal revenue code.
3. The participants will understand the specific reporting requirements for foreign taxes paid or accrued associated with various IRS forms, including Form 5471 and 1118, for the 2021 income tax year.

Webinar Description:

Listed below is an overview of the topics discussed in this webinar.

A – Creditability Matters
• Attribution Rule
• Net Gain Requirement
• Latest Administrative Guidance
B – Allocation and Apportionment
• DRE and CFC Regulations
• U.S. Shareholder Level Calculations
C – Reporting Requirements
• Form 1118
• Form 5471, including Schedule E and J
• Other

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: One (1)

Register:
https://lnkd.in/gmsmN6xY

Refunds: Due to this program being offered free of charge, there will be no refunds issued.

08/01/2022

Please join Forte International Tax, LLC for our upcoming webinar, “The ABC’s of Fully Integrated International Tax Modeling”, Wednesday, August 3rd @ 2pm CT.

Learning Objectives:

1. The participants will understand several essential international tax modeling concepts relevant throughout the planning, provision, and compliance tax department lifecycle.
2. The participants will receive statutory and administrative citations to support the calculations demonstrated during the webinar.

Description:
This session provides an interactive guide to essential international tax modeling scenarios using Forte’s VantagePoint™ software as the quantitative tool. The panelists will demonstrate specific examples throughout the planning, provision, and compliance lifecycle. The demonstration begins with international tax compliance and the resulting tax attributes and sourcing which serve as the foundation for all future modeling. Tax technical citations for the underlying calculations are provided and the Webinar provides one-hour of CPE credit.

For more information and to register, use the provided link:
https://lnkd.in/gfqNRCUr

Forte International Tax

11/14/2025

03/25/2024

01/03/2024

07/27/2023

06/05/2023

03/19/2023

02/28/2023

12/06/2022

09/13/2022

08/19/2022

08/01/2022

Address

Website

Alerts

Contact The Business

Shortcuts

Share

Category