What H.R.1, “OBBBA” (Commonly Known as “The Big Beautiful Bill Act”) Means for You and Your Clients: International Tax Update

Overview

The program will highlight the expanded surtax on certain foreign payments, the interaction of OBBBA provisions with the Base-Erosion and Anti-Abuse Tax (BEAT), and the compliance impact on U.S. companies with foreign shareholders. Attendees will learn

Highlights

Key Topics

• OBBBA surtax on foreign payments (IRC §899)
• Increased withholding and gross-basis tax rates on U.S.-sourced payments
• Removal of $500M gross receipts and 3% base erosion thresholds
• Application to U.S. corporations, partnerships, trusts, and private foundations
• Interaction with Base-Erosion and Anti-Abuse Tax (BEAT)
• Majority U.S. Owner Exception for U.S. multinationals and funds
• Compliance requirements and reporting risks
• Planning implications for cross-border transactions

Prerequisites

Basic understanding of federal individual and estate tax law

Designed For

Who Will Benefit

CPAs, EAs, tax professionals

Objectives

Learning Outcomes

• Identify how OBBBA expands surtaxes on U.S. payments to foreign recipients
• Recognize the elimination of gross receipts and base erosion thresholds under prior law
• Apply the revised rules to U.S. corporations with majority foreign ownership
• Determine when the Majority U.S. Owner Exception applies
• Assess how partnerships, trusts, and private foundations are impacted by new surtax provisions
• Evaluate planning considerations under the modified BEAT framework
• Assess and prepare to advise clients on compliance and reporting obligations created by the new law
• Identify risks and opportunities for U.S. multinationals and investment funds