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Global supply chains are undergoing significant transformation. In this episode of the EY Tax and Law in Focus podcast, we explore the evolving challenges and opportunities that businesses face in response to geopolitical shifts, new sustainability regulations, and advancements in AI and automation.Susannah Streeter is joined by Jay Camillo, EY Global Operating Model Effectiveness Leader; Alenka Turnsek, EY Global Sustainability Tax Policy Leader; and Kelly Stals, Principal in EY's International Tax Services and Operating Model Effectiveness Team. Together, they discuss how businesses can adapt their operating models, align tax strategies with supply chain shifts, and leverage emerging technologies to enhance efficiency and resilience.EY refers to the global organization, and may refer to one or more of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. The views of third parties set out in this publication are not necessarily the views of the global EY organization or its member firms. Moreover, they should be seen in the context of the time they were made.
Welcome to the latest episode of Beyond the Numbers by Weaver, hosted by Vince Houk, the Partner-in-Charge of International Tax Services at Weaver. Joining him is the adept Josh Finfrock, Director of Transfer Pricing Services at Weaver, ready to decode the intricate relationship between the IC Disc regime and transfer pricing.Key Points:Transfer pricing is not just a compliance aspect, but can be strategic and provide opportunities for tax savings and efficient cash management.A strategic review of a company's global structure can help identify transfer pricing opportunities and range of outcomes in different locations.Weaver can assist companies in identifying transfer pricing opportunities and operating their business more efficiently, while also mitigating risks through a holistic view of the company's operations.At the heart of this discussion is the Intercompany Pricing Agreement, commonly referred to as the IC Disc regime, which promises significant tax savings for exporters. But how can one optimize these benefits? And where does transfer pricing fit into this puzzle?IC discs are export incentives that provider for permanent tax savings and can benefit all entities from corporations to partnerships. However, the way most companies have IC discs set up, transfer pricing is often not required and utilized, but companies can benefit tremendously when they do decide to use transfer pricing. "We can take segment by segment, different expenses, and find categories that we think may be over allocating expense to that segment, which is increasing the benefit of the disc when you can find those opportunities," Finfrock explained.Subscribe and listen to future episodes of Weaver: Beyond the Numbers on Apple Podcasts or Spotify.©2023
On the latest episode of Beyond the Numbers by Weaver, host Vince Houk, Partner-in-Charge, International Tax Services at Weaver, delves deep into the world of strategic transfer pricing and how businesses can use it to their advantage. Joining him is Josh Finfrock, Director, Transfer Pricing Services at Weaver, an expert with a wealth of knowledge in the field. Key Points: One overlooked opportunity in utilizing FDII is to analyze the expense allocation with GNA expenses and allocate accordingly based on genuine benefit, which can help derive a better benefit. Other opportunities include looking at services provided by the U.S. company that may qualify for the FDII benefit and reviewing the IP structure to potentially move IP into the U.S. The U.S. provides a jurisdiction with substance, a good treaty network, and potentially lower tax rates compared to other countries, making it an attractive option for IP ownership and maintaining key operations. How can firms shift their perception and utilize transfer pricing as an asset rather than a burden? And what lies beyond the surface of transfer pricing, and how can businesses harness its potential to enhance their global operations? Clients often overlook how strategic transfer pricing can be and how it can be a tax saver and assist in cash management efficiency. For example, there is cash repatriation leakage that can be planned around with transfer pricing. Rate differentials between countries can be another challenge that transfer pricing adjustments can help save. Finfrock stated, “If we can do a strategic transfer pricing review with the company, we're going to come in and be able to look at, get a holistic view of the company, the global structure, understand where all the moving pieces are. That way, then we really know where those levers are, what our range of outcomes can be in different places, and then we can find those opportunities for savings.” Subscribe and listen to future episodes of Beyond the Numbers on Apple Podcasts or Spotify. ©2023
Highlighting Women's History Month in March, Buchanan hosted a thought-provoking discussion sharing the challenges and unique pathways to success from women across many industries. This discussion shares the various experiences of women in leadership roles and what steps are needed to develop more inclusive work environments for current employees and future ones. On this episode of Dimensions of Diversity host Lloyd Freeman talks with Serona Elton, Professor and Director, Music Industry Program at University of Miami Frost School of Music; Catherine Garrido, Regional Director (Americas), Global Institute of Sport; and Tansy Jefferies, Principal, International Tax Services, RSM US LLP. Dimensions of Diversity is a podcast created by Buchanan Ingersoll & Rooney, highlighting diversity in the workplace. Hosted by Lloyd Freeman, Chief Diversity & Inclusion Officer, the podcast features meaningful conversations with industry and community leaders working to advance D&I.
Tax Notes managing legal reporter Andrew Velarde breaks down the Supreme Court's oral arguments in Moore and predicts what's next for the case.For additional coverage, read these articles in Tax Notes:Government May Have Upper Hand in Moore, but Court May Go NarrowMoore Sold Shares in Transition Tax Company for Big GainMoores Fire Back That Macomber Is Controlling, Not Mere DictumTransition Tax Drafter: Quit It With ‘Mandatory Repatriation Tax'Small Business Groups Enter the Moore Fray in Defense of the TaxMoore Amicus Offers Supreme Court Off-Ramp From Realization QueryMacomber Dictum Not Controlling in Moore, Government SaysListen to our previous Moore episode: Moore Money, More Tax Problems? Analyzing Moore v. United StatesTo hear the full oral arguments, visit supremecourt.gov/oral_arguments/argument_audio/2023 In our “Editors' Corner” segment, Błażej Kuźniacki, senior manager at the International Tax Services at PwC Netherlands, chats about his Tax Notes piece, “Pillar 2 and International Investment Agreements: ‘QDMTT Payable' Seals an Internationally Wrongful Act.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart
In this episode of Weaver: Beyond the Numbers, On the Shop Floor podcast hosts Colby Horn and Kurtis Dixon examine the world of export incentives with Vince Houk, Weaver's partner-in-charge, International Tax Services. Together they discuss how companies can leverage these benefits to reduce taxes, offset costs and optimize their financial strategies.Key Points: • Export incentives yield permanent tax savings• IC-DISC and FDII offer tax advantages for international sales• Effective use of incentives boosts financial gainsExport incentives have emerged as a pivotal tool for companies, especially those in the M&D sector selling goods outside the U.S. These incentives offer permanent tax savings and mitigate unfavorable legislative changes such as R&D capitalization. This episode explores how businesses can maximize benefits, particularly after recent tax code changes. Vince emphasizes the importance of these incentives, specifically for maximizing benefits to offset costs. He further elaborates on the two main incentives from an export perspective, IC-DISC and FDII, explaining their nuances and potential benefits for different entities. IC-DISCs are for companies that manufacture in the U.S. and sell internationally. FDIIs are specifically for C corps that sell products outside of the U.S. to a foreign person for foreign use. With many clients engaging in significant international sales, Weaver regularly helps companies feel comfortable moving forward with these benefits. Subscribe and listen to future episodes of Weaver: On the Shop Floor on Apple Podcasts or Spotify.©2023
On the latest episode of Weaver: Beyond the Numbers, host Vince Houk, Partner-in-Charge of International Tax Services at Weaver, sits down with guest Josh Finfrock, Director of Transfer Pricing Services at Weaver. The two examined the impacts and implications of Brazil's recent legislative change on businesses engaged in cross-border activities. Key Points: Brazil recently adopted the OECD principles for transfer pricing, aligning their regulations with international standards. The new transfer pricing rules in Brazil will be mandatory in 2024 but can be opted into for 2023 if companies choose to do so. The new rules will allow companies to have a uniform method for transfer pricing globally, eliminating mismatches and potential double taxation. The essential shift in international taxation has emerged with Brazil's adoption of the Organisation for Economic Co-operation and Development (OECD) principles for transfer pricing. Historically, Brazil has stuck to a unique, formulaic approach to transfer pricing, often resulting in double taxation or exposure. However, with the adoption of OECD guidelines, the landscape is rapidly changing. This transition marks one of the most significant changes in the world of transfer pricing in years and holds the potential to reshape cross-border transaction dynamics. How does Brazil's alignment with OECD principles affect businesses? What should companies do to prepare for these changes and make the most of the new landscape? Some main points from the episode included: Understanding the switch from Brazil's unique formulaic approach to transfer pricing to the OECD's arm's length principle. The need for businesses to familiarize themselves with the new rules and implications for their tax preparations and economic analyses. The potential benefits of the new regulations, such as improved alignment with global transfer pricing arrangements and alleviation of double taxation. “The benefit of this is going to be companies can ideally have a uniform method with the rest of their global transfer pricing arrangements, right, where they may not have been able to deduct royalties or service expenses. These kinds of things had mismatches with customs and income tax in Brazil locally. Hopefully, this will allow them to align that better. Those are the kind of things that we need to be thinking about with our clients as well as the operational side of it,” said Finfrock. Josh Finfrock is a seasoned expert in Transfer Pricing, leading the practice at Weaver. His insights are grounded in years of experience navigating the complexities of international tax laws and regulations. Subscribe and listen to future episodes of Beyond the Numbers on Apple Podcasts or Spotify. ©2023
Artemis Live - Insurance-linked securities (ILS), catastrophe bonds (cat bonds), reinsurance
Establishing insurance-linked securities (ILS) investment management operations and the impact of recent international tax developments in the industry was the focus of our latest Artemis Live video interview. Our latest Artemis Live podcast episode is with Scott Slater of PwC, a Partner and the Tax Services Leader at PwC Bermuda. Scott also leads PwC in the Caribbean's International Tax Services group, which is based in Bermuda and the Cayman Islands. In this interview we discussed some recent international tax developments and how they could affect insurance, reinsurance and also insurance-linked securities (ILS) interests. Slater explained that a key area of focus for his practice and team, in relation to insurance-linked securities (ILS) market participants, is the controlled foreign corporation (CFC) rules and the passive foreign investment company (PFIC) rules. “In the ILS space, most of these structures are either CFC's or PFIC, and our practice specialises in giving the information that those US investors need to complete their tax returns and satisfy their reporting requirements for making that foreign investment,” he said. Slater also explained that a component of the work his team at PwC undertakes is to help ILS investment managers identify the right structures for their businesses, from a taxation point of view. “It's an interesting conversation, particularly with those asset manager backed ILS vehicles, to explain to them what has to happen in Bermuda and the people they need to get in Bermuda to satisfy those requirements, to mitigate the risk that they've somehow created a taxable presence in the US. “So we work with a lot of clients around the structure, but also the people functions and the activities that need to happen from Bermuda, to achieve that tax result,” he commented. Listen to this podcast episode for more insights from PwC Bermuda's Scott Slater.
On this episode of Weaver: Beyond the Numbers, host Tyler Kern discussed the proposed implementation of a Global Minimum Tax with Vince Houk, CPA, Partner-in-Charge, International Tax Services at Weaver. Houk explained that many countries within the OECD are considering certain measures, including a global minimum tax rate of 15 percent for larger companies because it would help to “level the playing field.” In addition to the competition between countries for tax revenue, many have seen the digital age hinder their ability to collect taxes. Together, these two issues have led to low tax rates worldwide and many countries are eager for changes. The Organization for Economic Cooperation and Development (OECD) is looking at three key rules to ensure that countries receive their fair share of taxes: 1. Income inclusion rule; 2. Undertaxed payments rule; and 3. Subject to tax rule The income inclusion rule and the undertaxed payments rule will effectively provide for a minimum rate of tax for multinational businesses, whereas the subject to tax rule will help ensure that a country's tax base is not eroded through certain deductible payments (interest, royalties, etc.) where the recipient country subjects the payment to a low rate of tax. While the income inclusion and undertaxed payments rule would affect multinational businesses with global revenue of more than 750 million euros, it is not clear whether the subject to tax rule will be subject to any threshold. Under the current framework, a key consideration for multinational businesses will be the effective tax rate which could, for example, impact a country's ability to boost their economies through tax incentives. These situations and more are issues the OECD must discuss and iron out before initiating the rule. While it's unclear why the members of the OECD are considering a 15 percent rate, it's evident it will apply to many large companies and may have a significant impact on their tax bill. Weaver's tax professionals are known for helping multi-national clients achieve global business growth. Listen to the full episode to hear all of Houk's insights, and visit weaver.com for more thought leadership. Subscribe and listen to future episodes of Weaver: Beyond the Numbers, The Business of Government on Apple Podcasts or Spotify.
Brooks and Sarah discuss the potential impact of proposed changes to U.S. based multinational companies with Cherry Bekaert's Brian Dill, Principal and International Tax Leader, and Michael Cornett, Director for International Tax Services. These proposed changes were introduced in the American Jobs Plan and further explained in Treasury's Green Book. The conversation covers proposed changes to FDII, GILTI, anti-inversion, and other tax rules intended to discourage moving business operations off shore. We also discuss the recent G7 and G20 agreements to pursue a 15% minimum global tax rate. Brian and Mike highlight common themes in tax policies across countries, and we wrap up with a few ideas and actions multinational companies should consider now.The conversation includes:2:45: Overview7:50: American Jobs Plan proposals and Green Book explanations19:55: A 15% global minimum tax rate29:13: Potential Impact to a company's global supply chain35:56: Final commentsRelated Guidance:Tax Beat: Treasury's Green Book Part 1Tax Beat: Treasury's Green Book Part 2Tax Beat: American Jobs Plan, 2021Tax Beat: American Families Plan
PwC professionals from our Tax and Deals practices for a timely discussion of the many factors impacting the current deals environment including the prevalence of ESG, the use of SPACs, and anticipated tax changes.The replay of the Tax Readiness: Preparing for Deals in a Changing Environment webcast is available here.Speakers:Julie Allen, National Tax Services Market Leader Craig Gerson, Partner, Mergers & Acquisitions Thomas Rees, Partner, Mergers & Acquisitions Carrie Parker, Partner, International Tax Services
Ken Kuykendall, PwC's US Tax Leader and Tax Consulting Platform Leader, speaks with Nita Asher and Pat Brown about the SHIELD proposal, what companies should be considering, and how companies can start planning now. Nita is a principal in PwC's International Tax Services practice, and Pat Brown is PwC's Washington National Tax Services Co-Leader. Learn more at PwC.com - https://www.pwc.com/us/policyondemand.Speakers:Ken Kuykendall, Tax Managing Partner, PwC USNita Asher, Principal, International Tax Services, PwC USPat Brown, Washington National Tax Services Co-Leader, PwC US
In this Concept Series episode, Nita Asher covers all things SHIELD: what does it stand for, what is its purpose, how does it work, how did the business community react, and what does its future look like? Learn more at https://www.pwc.com/us/policyondemandSpeaker:Nita Asher, Principal, International Tax Services, PwC US
In this episode we discuss that multinationals should expect significant changes in the tax environment from both US and non-US governments and organizations like the EU and the OECD. Additionally, a likely increase in the corporate tax rate would have major impacts on the GILTI and FDII rates and calculations. This, combined with global tax measures mean that multinationals must consider their global tax structure. These next six months are crucial for data-driven analysis and planning in order to understand options and react.The replay of the Tax Readiness: International tax planning post-election webcast is available here.Speakers: Julie Allen, Washington National Tax Services Market Leader Doug McHoney, International Tax Services Co-Leader Nita Asher, US Transfer Pricing Leader Paige Hill, a Principal in PwC’s International Tax Services practice
In this episode of Tap into Tax, Eileen Mullaney, Amanda McIntyre, and Andrew Jensen will talk about remote work trends and the importance of cross-functional collaboration with the Tax function to avoid risk and financial surprises later.Margie Dhunjishah, Tax Reporting & Strategy leader, PwC USEileen Mullaney, Principal, Global Mobility Consulting Leader, PwC USAmanda McIntyre, Principal, Global Mobility, PwC USAndrew Jensen, Partner, International Tax Services, PwC US
On this episode of Tap into Tax, Pat Brown, our Washington National Tax Services Co-leader, moderates a discussion surrounding the 2020 election results and the potential tax implications. Janice Mays from our Tax Policy Services group and Nita Asher from International Tax Services practice offer helpful insights on what to expect on the policy front in both the near and long term - focusing on the unfinished TCJA provisions, Biden campaign proposals, possible bipartisan tax measures, and the global tax environment. Speakers include:Pat Brown, Washington National Tax Services Co-Leader, PwC USNita Asher, Principal, International Tax, PwC USJanice Mays, Managing Director, Tax Policy Services, PwC US
Cut through the static of the international provisions of the Tax Cuts and Jobs Act (TCJA) with a discussion on what we learned during the first tax filing season, including Global Intangible Low-Taxed Income (GILTI) and more. Guest Chris Clifton joins host Damien Martin to reflect on key takeaways and look to what's ahead. Here's what's covered: The added complexity of the TCJA [01:25] The most surprising things about applying the international provisions [06:27] Section 956 [07:03] The new GILTI high-tax exception [09:26] Overpayments with §965 [12:27] Hybrid GILTI rule for partnerships and S corporations [14:34] Challenges with guidance on the 50 percent GILTI deduction with the §962 deduction [18:14] Areas where Chris is hoping to see more guidance [23:06] Approaching uncertainty after the TCJA [27:42] Discussing challenges and uncertainty with clients [29:36] Planning considerations for taxpayers after the TCJA [30:52] BIO FOR GUEST Chris Clifton is a managing director in BKD's International Tax Services division. His focus is on international tax planning and compliance for domestic, foreign and multinational corporations in areas such as foreign tax credits, subpart F, withholding taxes and income tax treaties. ADDITIONAL RESOURCES Learn more from Chris about some of the complex provisions discussed in the podcast: "Simply Tax" Episode 10: The International Side of Tax Reform with Chris Clifton (January 25, 2018) International Tax & the TCJA presented by Chris Clifton (February 22, 2018) New GILTI Regulations Include High-Tax Exception Election, Change for Partnerships & S Corporations by Chris Clifton (June 21, 2019) GET MORE “SIMPLY TAX” We're excited to also provide video content to strengthen your tax mind! Check it out on our new YouTube channel. A complete archive of our episodes is available on our website and YouTube playlist. We'd love to hear from you! Email feedback and questions to SimplyTax@bkd.com. Connect with Damien on social media! LinkedIn | Twitter | Instagram | YouTube
Cut through the static of the international provisions of the Tax Cuts and Jobs Act (TCJA) with a discussion on what we learned during the first tax filing season, including Global Intangible Low-Taxed Income (GILTI) and more. Guest Chris Clifton joins host Damien Martin to reflect on key takeaways and look to what’s ahead. Here’s what’s covered: The added complexity of the TCJA [01:25] The most surprising things about applying the international provisions [06:27] Section 956 [07:03] The new GILTI high-tax exception [09:26] Overpayments with §965 [12:27] Hybrid GILTI rule for partnerships and S corporations [14:34] Challenges with guidance on the 50 percent GILTI deduction with the §962 deduction [18:14] Areas where Chris is hoping to see more guidance [23:06] Approaching uncertainty after the TCJA [27:42] Discussing challenges and uncertainty with clients [29:36] Planning considerations for taxpayers after the TCJA [30:52] BIO FOR GUEST Chris Clifton is a managing director in BKD’s International Tax Services division. His focus is on international tax planning and compliance for domestic, foreign and multinational corporations in areas such as foreign tax credits, subpart F, withholding taxes and income tax treaties. ADDITIONAL RESOURCES Learn more from Chris about some of the complex provisions discussed in the podcast: "Simply Tax" Episode 10: The International Side of Tax Reform with Chris Clifton (January 25, 2018) International Tax & the TCJA presented by Chris Clifton (February 22, 2018) New GILTI Regulations Include High-Tax Exception Election, Change for Partnerships & S Corporations by Chris Clifton (June 21, 2019) GET MORE “SIMPLY TAX” We’re excited to also provide video content to strengthen your tax mind! Check it out on our new YouTube channel. A complete archive of our episodes is available on our website and YouTube playlist. We’d love to hear from you! Email feedback and questions to SimplyTax@bkd.com. Connect with Damien on social media! LinkedIn | Twitter | Instagram | YouTube
Founder of Grasmeier Business Services LLC, Marie Grasmeier is a Certified Public Accountant providing tax and consulting services to domestic and international individuals and businesses. Marie is also a Certified Management Accountant, Certified Global Management Accountant and a Registered Trust and Estate Practitioner. She specializes in assisting foreign investors with their US tax and compliance needs and also enjoys working with entrepreneurs through the entire lifecycle of a business from start-up to succession planning. Having spent most of her career in International Tax Services, she assists foreign investors comply with the Foreign Investment in Real Property Tax Act, Tax Treaties, and assists with financial projections for visa applications and structuring of real estate investment schemes. She helps clients in selecting the optimal investment strategy based on investable assets, risk tolerance, short, mid and long-term goals, exit strategy and available tax credits and incentives. In this episode, Michelle Bosch chats to Marie about her career, how she grew up around money & finances and why she's excited about real estate. You'll also get some detailed advice into Opportunity Zones - a new investment tool which encourages long-term investments in low-income urban and rural communities. You'll find out how to utilize Opportunity Zones, in order to save on your taxes! What's inside: Find out about Marie Grasmeier's career Discover how to utilize Opportunity Zones to save on your taxes Understand how Marie incorporates faith & spirituality into her life Learn the common pitfalls that many people face when investing in real estate Find out more! Subscribe and rate our podcast on iTunes at: http://www.michellebosch.com/itunes Android users can subscribe and rate our podcast at: http://www.michellebosch.com/android Follow Michelle Bosch on Instagram to see what she's up to: https://www.instagram.com/michelleboschofficial/ Check out Marie Grasmeier's website: http://www.mariecpa.com Get in touch with Marie via email: marie@mariecpa.com
Medvirkende: Malte Søgaard, Senior Manager for EY's afdeling for International Tax Services I denne særudgave af Magtens Tredeling besøger vi de jurister, der arbejder på den anden side af bordet - nemlig juristerne i det danske erhvervsliv. I dette afsnit er K-News taget til revisionshuset EY. Her møder vi Senior Manager for EY's afdeling for International Tax Services Malte Søgaard, som sidder på den rådgivende side af bordet, når han som jurist vejleder kunder og internationale medarbejdere inden for skatteret.
Businesses and their owners have a lot on their wish lists this tax planning season thanks to the Tax Cuts and Jobs Act (TCJA). Just in time for “TCJA-mas,” host Damien Martin calls in some help from guests Ed Karl, Jesse Palmer and Justin Stenberg to respond to a few TCJA-related wishes from businesses, their owners and their advisors. They’ll explore guidance, accounting methods and considerations for multinational companies after the TCJA. Here’s a list of questions covered: Guest Ed Karl [ 01:26 ] Will we have answers and guidance before filing season? [ 03:31 ] How can a CPA add value to businesses and their owners? [ 04:09 ] What’s the employer credit for paid family and medical leave? Guest Jesse Palmer [ 06:50 ] Can a cash basis small business taxpayer deduct inventory after the TCJA? [ 12:38 ] How does Section 451(b) change the recognition of income? Guest Justin Stenberg [ 19:00 ] What action should U.S. CFC shareholders consider before year-end? [ 27:44 ] Why do you need to consider a basis election under the §965 guidance? [ 32:06 ] How has foreign reporting changed under the TCJA? [ 35:48 ] What could changes to the foreign tax credit under the TCJA mean for credit carryovers? [ 40:08 ] What are some international considerations for choice of entity? [ 47:48 ] Is it true multinational companies aren’t subject to tax on their foreign earnings with the 100 percent dividend received deduction? [ 51:31 ] Why are E&P studies important right now? BIOS FOR GUESTS Justin Stenberg is a member of BKD’s International Tax Services division and has more than 11 years of experience providing tax services to clients in the manufacturing, distribution, software and service industries. He has worked closely with privately held and publicly traded corporations. Connect with Justin on LinkedIn Jesse Palmer is a tax partner at BKD and serves as director of tax quality control in the firm’s National Office Tax Department. His responsibilities include quality control, risk management and day-to-day administration of the firm’s national tax practice. Jesse works closely with the national tax director on firmwide tax quality control projects and support-related tasks. Connect with Jesse on LinkedIn Ed Karl is vice president of taxation at the AICPA. He’s responsible for the review, formulation and submission of technical and policy recommendations for improvement of the federal tax process to Congress, the U.S. Department of the Treasury and the IRS. Ed also serves as a principal liaison for the AICPA with the IRS and is responsible for tax ethical issues, which includes managing the AICPA’s Statements on Standards for Tax Services. Finally, Ed oversees the tax division’s delivery of services to members, focusing on helping AICPA members provide the highest quality professional tax services. Follow Ed on Twitter | Connect with Ed on LinkedIn ADDITIONAL RESOURCES “Released Guidance Sheds Light on Employment Provisions” by Katie Patton “GILTI Year-End Restructuring Considerations for U.S. CFC Shareholders” by Chris Clifton GET MORE “SIMPLY TAX” A complete archive of our episodes is available on our website and YouTube playlist. We’d love to hear from you! Email feedback and questions to SimplyTax@bkd.com. Connect with Damien on social media! LinkedIn | Twitter | Instagram
Businesses and their owners have a lot on their wish lists this tax planning season thanks to the Tax Cuts and Jobs Act (TCJA). Just in time for “TCJA-mas,” host Damien Martin calls in some help from guests Ed Karl, Jesse Palmer and Justin Stenberg to respond to a few TCJA-related wishes from businesses, their owners and their advisors. They'll explore guidance, accounting methods and considerations for multinational companies after the TCJA. Here's a list of questions covered: Guest Ed Karl [ 01:26 ] Will we have answers and guidance before filing season? [ 03:31 ] How can a CPA add value to businesses and their owners? [ 04:09 ] What's the employer credit for paid family and medical leave? Guest Jesse Palmer [ 06:50 ] Can a cash basis small business taxpayer deduct inventory after the TCJA? [ 12:38 ] How does Section 451(b) change the recognition of income? Guest Justin Stenberg [ 19:00 ] What action should U.S. CFC shareholders consider before year-end? [ 27:44 ] Why do you need to consider a basis election under the §965 guidance? [ 32:06 ] How has foreign reporting changed under the TCJA? [ 35:48 ] What could changes to the foreign tax credit under the TCJA mean for credit carryovers? [ 40:08 ] What are some international considerations for choice of entity? [ 47:48 ] Is it true multinational companies aren't subject to tax on their foreign earnings with the 100 percent dividend received deduction? [ 51:31 ] Why are E&P studies important right now? BIOS FOR GUESTS Justin Stenberg is a member of BKD's International Tax Services division and has more than 11 years of experience providing tax services to clients in the manufacturing, distribution, software and service industries. He has worked closely with privately held and publicly traded corporations. Connect with Justin on LinkedIn Jesse Palmer is a tax partner at BKD and serves as director of tax quality control in the firm's National Office Tax Department. His responsibilities include quality control, risk management and day-to-day administration of the firm's national tax practice. Jesse works closely with the national tax director on firmwide tax quality control projects and support-related tasks. Connect with Jesse on LinkedIn Ed Karl is vice president of taxation at the AICPA. He's responsible for the review, formulation and submission of technical and policy recommendations for improvement of the federal tax process to Congress, the U.S. Department of the Treasury and the IRS. Ed also serves as a principal liaison for the AICPA with the IRS and is responsible for tax ethical issues, which includes managing the AICPA's Statements on Standards for Tax Services. Finally, Ed oversees the tax division's delivery of services to members, focusing on helping AICPA members provide the highest quality professional tax services. Follow Ed on Twitter | Connect with Ed on LinkedIn ADDITIONAL RESOURCES “Released Guidance Sheds Light on Employment Provisions” by Katie Patton “GILTI Year-End Restructuring Considerations for U.S. CFC Shareholders” by Chris Clifton GET MORE “SIMPLY TAX” A complete archive of our episodes is available on our website and YouTube playlist. We'd love to hear from you! Email feedback and questions to SimplyTax@bkd.com. Connect with Damien on social media! LinkedIn | Twitter | Instagram
The Globig podcast guest is Shannon Lemmon, a Partner and specialist in International Tax Services at Eide Bailly, one of the top accounting firms in the US. The new Republican tax bill went into effect January 2018 and it significantly impacts US international tax rules. It’s been said the new bill represents the largest overhaul of the US tax code since 1986. Shannon helps us to understand what the biggest changes are to US International Tax Rules and what impact those changes will have.
We’re back to help you cut through the static of the Tax Cuts and Jobs Act with the second in a series of episodes that breaks down what the new tax law means for you and your business. BKD’s Chris Clifton covers the international provisions of the new tax law and explains how they fit into the larger world of international taxation. Some of the important areas covered in this episode include: Shift to a territorial system @ 2:28 Deemed repatriation @ 4:17 Global intangible low-taxed income (GILTI) @ 10:27 Base erosion anti-abuse tax (BEAT) @ 14:08 Limitation on deduction for interest expense @ 18:50 Areas where additional guidance is needed @ 22:25 Foreign derived intangible income (FDII) @ 29:27 International considerations for converting an S corp to a C corp @ 36:42 Key takeaways @ 40:25 BIO FOR GUEST Chris Clifton is a managing director in BKD’s International Tax Services division. His focus is on international tax planning and compliance for domestic, foreign and multinational corporations in areas such as foreign tax credits, subpart F, withholding taxes and income tax treaties.
We're back to help you cut through the static of the Tax Cuts and Jobs Act with the second in a series of episodes that breaks down what the new tax law means for you and your business. BKD's Chris Clifton covers the international provisions of the new tax law and explains how they fit into the larger world of international taxation. Some of the important areas covered in this episode include: Shift to a territorial system @ 2:28 Deemed repatriation @ 4:17 Global intangible low-taxed income (GILTI) @ 10:27 Base erosion anti-abuse tax (BEAT) @ 14:08 Limitation on deduction for interest expense @ 18:50 Areas where additional guidance is needed @ 22:25 Foreign derived intangible income (FDII) @ 29:27 International considerations for converting an S corp to a C corp @ 36:42 Key takeaways @ 40:25 BIO FOR GUEST Chris Clifton is a managing director in BKD's International Tax Services division. His focus is on international tax planning and compliance for domestic, foreign and multinational corporations in areas such as foreign tax credits, subpart F, withholding taxes and income tax treaties.
Dette er en særudsendelse med fokus på den netop vedtagne skattereform i USA. Søren Jesper Hansen, Head of International Tax Services og partner i PwC, fortæller om: - Baggrunden for reformen. - De vigtigste ændringer i den amerikanske skattelovgivning. - Hvilken betydning reformen får for danske virksomheder, der handler med USA. Vært: Magnus Krabbe