Foreign Subsidiaries of Multinational Businesses: GILTI, Hybrid Entities, Form 5492, and Recent Transfer Pricing Cases
Recording of a 110-minute CPE webinar with Q&A
This course will explore the tax difficulties faced by multinational companies with foreign subsidiaries. The panelist of veteran foreign tax professionals will discuss the compliance challenges these businesses face, including recent transfer pricing cases, Section 894(c) payments made by hybrid entities, and impending changes to the current foreign taxation regime.
- Foreign subsidiaries
- Transfer pricing
- FDII, FDDEI, and related-party sales
- 864(c) anti-hybrid rules
- Form 5472
- Impending changes
- Best practices
The panelist will review these and other critical issues:
- How related party transactions qualify as FDDEI transactions under the final regulations
- Action items for multinational companies from current transfer pricing cases
- What transactions between related entities are required to be reported on Form 5472?
- How would proposed legislative changes impact the taxation of multinational entities?
Raul A. Escatel, J.D., LL.M.
Ascendant Law Group
Mr. Escatel brings extensive experience and close personal attention to the representation of businesses and... | Read More
Mr. Escatel brings extensive experience and close personal attention to the representation of businesses and individuals in a broad range of tax matters, both as an advisor and as an advocate. He has an established track record of successfully representing his clients in significant income tax, sales and use tax, and employment tax issues before the IRS, the California Franchise Tax Board, and various administrative and local taxing agencies. Further, Mr. Escatel is certified as a Tax Specialist by the State Bar of California Board of Legal Specialization.Close