Chad Rowland will speak on the D.C. Bar panel "Recent Proposed Regulations Implementing International Tax Provisions of the One Big Beautiful Bill Act" on September 22, 2026. The panel is the first in a four-part international tax series. Panelists will discuss recently proposed rules for determining pro rata share for purposes of subpart F and Net CFC Tested Income (NCTI), applying the new exclusion to Foreign-Derived Deduction-Eligible Income (FDDEI), allocating foreign taxes of foreign corporations affected by the repeal of the one-month deferral election, and disallowing foreign tax credits on certain Previously Taxed Earnings and Profits (PTEP) distributions. If released before the event, the panel will also address guidance on foreign tax credit expense allocation under Section 904(b)(5).