Beyond Borders: Navigating H.R. 1’s New International Tax Rules

Tax

Webcast

Beyond Borders: Navigating H.R. 1’s New International Tax Rules

Part of the H.R. 1 Tax Masterclass Series, this session covers international tax changes — Sec. 250, Sec. 951A, BEAT, Foreign Tax Credits, Sec. 958(b)(4), remittances tax and planning for cross-border ops and repatriation.

$59 - $89

Do you have an AICPA or CIMA membership? Log in to apply your member discount.

Format

Webcast

Date

Nov 04, 2025

NASBA Field of Study

Taxes

Level

Intermediate

CPE Credits

Instructor

Jeshua Wright, Jeff Driesen, JP Gregorcy, Cory Perry, Andy Mattson

Availability

3 months

Product Number

WC5041414

View

Business & partner

Part of a discounted

Product Details

Get up to speed on the international tax provision overhaul in H.R. 1, P.L. 119-21, commonly referred to as One Big Beautiful Bill Act or OBBBA, in this concise 1-hour session, part of the H.R. 1 Tax Masterclass Series.

We’ll cover:

Rate adjustments to Sec. 250 (formerly foreign derived intangible income or FDII) and Sec. 951A (formerly global intangible low-taxed income or GILTI) and base erosion and anti-abuse tax (BEAT) rules;
Modifications to the foreign tax credit (FTC) rules under sections 904 and 960, including sourcing inventory sales and haircuts to taxes deemed paid attributable to previously taxed earnings and profits.

You’ll learn how reinstatement of Sec. 958(b)(4) drastically reduces Form 5471 filings, simplifying compliance related to U.S. shareholder inclusions.

We’ll close with practical planning considerations for cross-border operations and tax-efficient repatriations.

Key Topics

Rate shifts and other adjustments to Sections 250 and 951A, BEAT, FTC changes
Reinstatement of Sec. 958(b)(4); the reduction in Form 5471 filings; new Section 951B; and potential increase in application of passive foreign investment company rules

Learning Outcomes

Calculate impacts due to rate adjustments and other international provisions.
Identify effective tax changes for outbound investment and U.S. multinational planning.
Identify base erosion payments and structure transactions to minimize BEAT exposure to effectively navigate BEAT.
Calculate the reduction in Form 5471 filings and streamline U.S. shareholder reporting requirements by leveraging Sec. 958(b)(4) relief.

Who Will Benefit

CPAs
Tax practitioners
Small firms
Medium firms
Large firms
Sole practitioners

Bundle and Save

Bundle this session with the remaining four in the HR. 1 Tax MasterClass Series to access all 5 classes, earn 10 CPE credits, and receive a 20% discount compared to stand-alone pricing.

For a more comprehensive learning experience, combine the H.R. 1 Tax MasterClass Series with the HR. 1 PFP MasterClass Series — featuring 5 classes, 7 CPE credits, and a 25% discount off stand-alone course pricing.

Together, they form the H.R. 1 MasterClass Series Bundle: 8 classes, 15 CPE credits, and an additional 13% discount when purchased as a combined bundle.

Credit Info

CPE Credits

NASBA Field of Study

Taxes

Level

Intermediate

Prerequisites

Fundamental knowledge of the new H.R. 1 tax bill, commonly referred to as OBBBA.

Access

This is a digital product. With full paid access the content will be available to you for 3 months after purchase date.

Duration

1 hr

For more information, please refer to CPE requirements and NASBA sponsorship information

Pricing

Do you have an AICPA or CIMA membership? Log in to apply your member discount.

Nonmembers

$89.00

AICPA Members

$69.00

CIMA Members

$69.00

PFP Section Members

$59.00

Tax Section Members

$59.00

Group ordering for your team

2 to 5 registrants

Save time with our group order form. We’ll send a consolidated invoice to keep your learning expenses organized.

Start order

6+ registrants

We can help with group discounts. Email client.support@aicpa-cima.com
US customers call 1-800-634-6780 (option 1)

Speakers

Jeshua Wright

CPA

Jeshua Wright, CPA, is a member of Ernst & Young LLP’s International Tax and Transaction Services practice, specializing in international tax planning. He leads Ernst & Young’s International Tax Quantitative Services (ITqS) Advisory practice. He has been with Ernst & Young since 2012 and been a member of the firm’s National Tax Department since 2018. Jeshua has extensive international tax experience advising clients on legislative and regulatory developments, foreign tax credit planning, outbound inclusion regimes, cross-border mergers and acquisitions, internal restructurings, CAMT, and Pillar 2. He also has experience in preparing and reviewing international components of client tax provisions. Jeshua holds a Master of Accountancy and Bachelor of Science in Accounting from Brigham Young University and is a CPA licensed in North Carolina and Washington, DC. He is a member of the American Institute of Certified Public Accountants (AICPA).

Jeff Driesen

Jeff Driesen, JD, is a Principal of International Tax at Baker Tilly, and based in San Francisco. He has 17+ years of providing consultation on various aspects of US centric international tax, including global expansion, cross-border acquisition and disposition planning, legal entity restructuring, offshore intellectual property and principal operating company structures, foreign tax credit planning, repatriation strategies, subpart F income, IRS tax controversies, US tax compliance, and the impacts of 2017’s TCJA and 2025’s OBBBA (GILTI, FDII, and BEAT). Jeff has been a frequent presenter at tax seminars and training facilities on numerous international tax topics, including US tax reform, intellectual property planning, supply chain alignment, and OECD/BEPS/EU tax law considerations

JP Gregorcy

CPA

JP Gregorcy, CPA, is a Director in the Washington National Tax Services practice of PwC US Tax LLP. He has experience working with both public and private companies and focuses on cross-border reorganizations, third party acquisitions/divestitures, post-acquisition restructuring, foreign tax credits, expense apportionment, dividends received deduction issues, and other inbound/outbound issues. Prior to rejoining PwC, JP was the Director of Global Tax Planning for McDonald’s Corporation, responsible for providing US and international tax expertise on transactions, managing provision processes related to transactional matters, coordinating interaction with government relations and legislative contacts, and managing various tax controversy matters. Before his role with McDonald’s, JP worked with PwC, including a tour with the National Tax Services practice.

Cory Perry

CPA

Cory Perry, CPA, is a Principal of International Tax at the Washington National Tax Office of Grant Thornton. He consults on various international and transactional tax matters, including cross-border restructuring and financing, subpart F, global intangible low-taxed income, foreign tax credit planning, Pillar 2 and global tax strategy. Cory’s work focuses on international quantitative consulting, as well as consulting services for mergers and acquisitions. He has significant experience performing earnings and profits studies and foreign tax credit studies for companies ranging up to large public and private clients, including Fortune 100 companies. Cory has written, spoken and lectured on a wide variety of topics including tax reform, subpart F, global intangible low-taxed income, section 367, and financial statement implications for U.S. multinationals. In addition to his work at Grant Thornton, Cory is chair of the AICPA’s International Tax Resource Panel and its OECD Task Force, where he helps guide the profession’s engagement with emerging international standards.

Andy Mattson

CPA

Andy Mattson, CPA is a Principal at Baker Tilly and has been providing tax solutions to start-ups and other technology companies in Silicon Valley since 1985. Andy is an appointed member of the AICPA’s Tax Executive Committee. He is also the Chair of CalCPA’s Committee on Taxation. Andy is the founder and leader of Baker Tilly’s Latin America Practice.

Accessibility

The Association is dedicated to removing barriers to the accountancy profession and ensuring that all accountancy professionals and other members of the public with an interest in the profession or joining the profession, including those with disabilities, have access to the profession and the Association's website, educational materials, products, and services.The Association is committed to making professional learning accessible to all product users. This commitment is maintained in accordance with applicable law. For additional information, please refer to the Association's Website Accessibility Policy. As part of this commitment, this product is closed-captioned. For additional accommodation requests please contact adaaccessibility@aicpa-cima.com and indicate the product that you are interested in (title, etc.) and the requested accommodation(s): Audio/Visual/Other. A member of our team will be in contact with you promptly to make sure we meet your needs appropriately.