Name
International Taxation: A Discussion of the OBBBA’s Changes to the Controlled Foreign Corporation Rules
Speakers
Joshua Odintz, Holland & Knight LLP
Layla Asali, Miller & Chevalier Chartered
Ron Dabrowski, KPMG US LLP
James Kostura, Internal Revenue Service
Jim Wang, U.S. Department of the Treasury
Layla Asali, Miller & Chevalier Chartered
Ron Dabrowski, KPMG US LLP
James Kostura, Internal Revenue Service
Jim Wang, U.S. Department of the Treasury
Date & Time
Wednesday, January 7, 2026, 9:00 AM - 10:15 AM
Description
This panel will address the changes made by the OBBB to the outbound The OBBB changed the date for a controlled foreign corporation’s (CFC) tax year, and the panel will discuss transition rules under Notice 2025-72. U.S. Shareholders of a CFC will now receive their pro-rata share of CFC income earned over the course of the year, which is addressed in Notice 2025-74. The panel will discuss the changes to the regime formerly known as GILTI, the restoration of section 958(b)(4), and new section 951B.
Virtual Session Link