Layla Asali, Robert Kovacev, and Jeffrey Tebbs will speak at the Tax Executives Institute (TEI) Houston Chapter International Tax Update on February 11, 2025.

Asali and Tebbs will present the session, "Cross-Border Cash Management." They will discuss tax considerations for managing a global treasury function and highlight traps for the unwary, including open issues on the availability of the Section 245A dividends received deduction and unresolved questions on previously taxed earnings and profits (PTEP). They will also review the proposed PTEP regulations expected to be released at the end of 2024, along with other recent developments, including administrative guidance on covered inbound transactions (Notice 2024-16) and mid-year distributions of PTEP.

Kovacev will co-present the session, "International Controversy Update." This presentation delves into the complexities of current and emerging international tax controversies, emphasizing key topics such as the IRS’s and courts’ evolving approaches to economic substance issues and recent controversies involving cross-border service fees. The discussion also highlights several high-profile cases which may provide a roadmap for navigating the evolving international tax landscape.