FDII/Section 163(j)
TRS Reform Campaign
TRS Miscellaneous


A US person that owns 10% or more of the total voting power or value of a foreign corporation.

What is a US shareholder?


What does BEAT stand for?

What is Base Erosion and Anti-Abuse Tax


For purposes of applying the $25M gross receipts test of the small business exemption, how often is testing required? (163j)

What is every tax year?


The location of where the International Tax Calculation, Data and Technology Services, Tier 1 Campaign materials are stored

What is Tax Source?


Name the two East Region Leaders

Who are Hadley Leach and David Wiseman


When properly allocable deductions exceed gross tested income.

What is tested loss?


What percentage of ownership is the general threshold for a taxpayer to qualify as a related party within the BEAT provisions?

What is 25%


The FDII deduction is reduced to 21.875% effective for:
A. Taxable years beginning after December 31, 2021.
B. Taxable years beginning before December 31, 2015.
C. Taxable years beginning after December 31, 2025.
D. Taxable years beginning after December 31, 2017.

What is C, Taxable years beginning after December 31, 2025.


 The location of where the Extract, Transform, Load (ETL) Accelerator is stored?

What is Digital Lab?


This concept is described as expanding our natural alliance with advisory, increasing teaming within Tax LoS, and leveraging tax function of the future

What is One firm approach


The quarterly average of a CFC's adjusted basis in tangible depreciable property used in the CFC's trade or business

What is QBAI (qualified business asset investment)?


What are the three criteria to qualify as an Applicable Taxpayer in 2019?

What is; Any corporation other than a RIC, REIT or S-Corp, Average annual gross receipts for the most recent three-year period greater than $500M, a base erosion percentage greater than 3%


The FDII deduction is available to which types of taxpayers?
A. All corporations and partnerships
B. C corporations that are not RICs or REITs
C. C corporations and individuals
D. None of the above

What is B, C corporations that are not RICs or REITs


The name of the QST modeling tool

What is Beacon Platinum?


Name 3 out of the 5 PwC Network values

What are - Act with integrity, make a difference, care, work together, and reimagine the possible



The US tax on GILTI can be partially offset by this amount of deemed paid foreign tax credit related to this CFC's GILTI.

What is 80%


Under the proposed regulations, what is the BEAT tax rate for a FYE 9/30/19 taxpayer?

What is 8.75%


True / False ...

Section 163(j) applies regardless of whether the interest payment is made to a US or foreign person, or whether the recipient of interest is exempt from US tax.

What is true?


The TRS product code for Data Accelerator engagements

What is US440?


Name three out of the six areas of focus for tax and finance in 2019

What is Adapting to US tax reform and policy changes, upskilling your workforce, aligning with customs and trade, embracing small automation, re-evaluating the operating structure, recognizing AI & Machine Learning


The value to be placed in the last row

What is $312,500?


Calculate the total US tax liability using the following facts, Revenue $5000, COGS $450, BEAT payments $200, Other Deductions $750

Revenue: $5,000

Base Erosion % 21%

COGS ($450)

Modified TI $3,800

BEAT ($200)

Other ($750)

TI $3,600

Tax Rate 21%

Tax Rate 10%

Tax Exp $756

BEAT Tax $380

US Tax Expense $ ?



Corporation A has adjusted taxable income of $30,000, business interest income of $1,000 and interest expense of $12,000 with no floor plan financing interest for tax year 2018. What amount of interest expense can Corporation A deduct in 2018 and what amount can be carried forward to 2019 if any?  

What is...

2018 interest deduction - 10,000

2019 carried forward amount - 2,000 


The five phases of a Tax Reform Data Solutions Project

What is assessment, data inventory, design automation, approach, integrate, governance?


ERP/EPM - tax sensitization is a new offering of this TRS vertical

What is TRS for tax accounting