GILTI, FDII, and BEAT: Post Tax Reform Planning Ideas and Tools for Multinationals

Venue

This is a virtual event, accessible on-line and over phone. Access instructions will be provided after registration.

Description

This is a complimentary program sponsored by TMF Group.

From a U.S. perspective, tax reform aligns closely with President Trump’s Make America Great Again agenda and his drive to encourage companies to invest in the U.S. Tax reform has been received positively by U.S. businesses, and the massive reduction in the U.S. corporate tax rate from 35% to 21% alone now gives the U.S. a competitive tax regime.

But the devil is in the details and there are a number of big ticket items that taxpayers should understand – that will be the subject of this 60-minute webinar. They include:

Base Erosion Anti-Abuse Tax (BEAT)
Attracting a lot of interest and taxpayer questions, BEAT applies a 10% minimum tax for taxable income adjusted for base erosion payments. It only applies when U.S. gross receipts exceed $500 million, aggregated on a global group basis.

Global Intangible Low-Taxed Income (GILTI)
Another anti-base erosion measure that targets U.S. corporations that owned CFCs for U.S. tax purposes, providing for a current income inclusion regime similar to the pre-existing Subpart F regime.

Foreign–derived Income Attributable to Intangibles (FDII)
FDII, the flip side of GILTI, allows a deductible for foreign-derived income attributable to intangibles. The rules provide for a deduction of 37.5% from income resulting in an effective U.S. tax rate of 13.125%, thus benefiting U.S. intellectual property that generates foreign income.

Join subject matter experts from TMF Group and DLA Piper for this important discussion and gain an understanding of the following:
• How tax reform impacts IP valuations for inbound and outbound transfers
• Different FDII and GILTI scenarios 
• When does IP migration or cost sharing still work
• What we are seeing in the market

Educational Objectives:
Key Takeaways – participants will gain an understanding of the following
• How tax reform impacts IP valuations for inbound and outbound transfers
• Different FDII and GILTI scenarios 
• When does IP migration or cost sharing still work
• What we are seeing in the market

Who would benefit most from attending this program?
Attorney/Counsel, Controller/Comptroller, CPA/Accountant, CEO/President, General Counsel

Presenters

Larry Harding
  • President Consultancy Solutions
  • TMF Group

Larry joined TMF Group in August 2017 as President of the new division, Consultancy Solutions. He joins after having founded and, as CEO of High Street Partners (HSP) since 2003. HSP went on to become an entrepreneurial success over the ensuing decade, ranking twice consecutively on the Inc 500 as one of the fastest growing companies (#84 and #79) in the US, and fundraising more than $20m in venture capital proceeds. The success of HSP saw Larry win EY’s prestigious Entrepreneur of the Year award for the Maryland region in 2013, and in the following year he managed the successful exit of the business as part of a private equity backed merger transaction. Previously he was Senior Audit Manager and M&A consultant with Ernst and Young in Boston, was CFO for several Boston area high tech companies, and served as VP of International Finance for CIENA Corporation.

Jason Gerlis
  • Regional Director, North America & Caribbean
  • TMF Group

Jason is responsible for TMF Group client delivery in the USA, Canada, BVI, Curacao and Cayman Islands where his teams support businesses expanding, or investing into the region. He is an experienced Corporate Director who regularly advises USA and Canadian businesses looking to expand abroad, as well as foreign companies and individuals coming to North America. Jason has been with TMF Group for four years, first based in London, but relocated to Miami, Florida in November 2014. Previously he worked at Deloitte Consulting LLP and Tesco PLC specialising in strategy, change management and Operating Model Development. Jason is a graduate of the University of Oxford and a Black Belt in Lean Six Sigma.

Maruti Narayan
  • Partner
  • DLA Piper, New York City

Maruti Narayan, Partner, DLA Piper, New York City advises US and foreign-based multinationals on a broad range of international tax matters, including supply chain structuring, IP migration, US income tax treaties and cross-border mergers and acquisitions.  Maruti earned a B.A. from Yale University and a J.D. from the University of Virginia School of Law.

Philip Rogers
  • Partner
  • DLA Piper, New York

Philip Rogers, Partner, DLA Piper, New York City has practiced international tax law since 1983 and concentrates his practice in international tax, including legal and operational structuring, general international tax planning matters, global transfer pricing strategy and documentation, cross-border mergers, acquisitions, dispositions and joint ventures, and international tax controversy. He has led dozens of international structuring projects for companies across a wide spectrum of industries and jurisdictions, and his clients include leaders in the financial, high technology and consumer products industries.

Before joining DLA Piper, Philip was with a Big 4 accounting firm, where he represented numerous Fortune 100 companies in their international tax planning, advising them on a broad range of cross-border issues, including international restructuring, post-merger and post-acquisition integration, repatriation planning, global supply chain planning and IP migration.

Continuing Education

Credits:
COA, 1.0 CLE
Practice Areas:
Tax
Prerequisite:
Basic knowledge of international tax laws.
Level:
Intermediate
Production Date:
03/15/2018