Banks and the International Provisions of the 2017 Tax Act at the ABA 2018 Fall Tax Meeting

Orrick Tax Partner Peter Connors will be a panelist at the 2018 Fall Tax Meeting, presented by ABA Section of Taxation and the Trust and Estate Law Division of the ABA Section of Real Property, Trust and Estate Law.

Peter will participate in the panel for "Banks and the International Provisions of the 2017 Tax Act". The panel will discuss the effect of amended subpart F rules, global intangible low-taxed income (“GILTI”) inclusion, and the base erosion and anti-abuse tax (“BEAT”) on domestic and foreign banks. Subjects will include downward attribution, allocation of expenses and its effect on GILTI foreign tax credits, and financing of US banks by foreign affiliates. Current and potential future IRS and Treasury guidance will be considered.