Transnational Transfer Pricing Implications of Tax Reform
This program has been cancelled
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide guidance on the implications of the 2017 tax law on cross-border transfer pricing. The panel will discuss the ways in which the reduction of the U.S. top corporate tax rate, combined with BEAT regulations and the introduction of a modified territorial tax system, create both opportunities and different risks than companies have previously associated with transfer pricing. The webinar will outline strategies to optimize the tax treatment of cross-border transactions.
- Prior transfer pricing landscape
- Impact of change to a modified territorial tax regime under the 2017 tax law on transfer pricing
- Participation exemption and opportunities for tax arbitrage
- The intersection of BEAT and transfer pricing rules
- Possibility of using corporate rate reduction to resolve transfer pricing controversies arising prior to 2018
The panel will discuss these and other relevant topics:
- How the tax landscape has--and hasn't--changed for U.S.-based MNEs and their transfer pricing structure
- What role might transfer pricing adjustments have on an MNE's calculation of the deemed repatriation "toll charge" tax?
- Impact of GILTI and FDII on an MNE's assessment of the effectiveness of existing transfer pricing strategies
- Areas of uncertainty remaining in transfer pricing adjustments from periods prior to 2018
John Garcia, CPA
Corporate Tax Advisors
Mr. Garcia specializes in providing accounting, tax, and training services for mid-sized corporations with an... | Read More
Mr. Garcia specializes in providing accounting, tax, and training services for mid-sized corporations with an international footprint. Prior to starting his firm, he served as the head of tax for various large global consumer products companies for over a decade. In these roles he was responsible for all income tax planning, financial reporting, compliance and audits. He has a wealth of experience including settling multiple full scope international IRS audits and appeals, competent authority proceedings, and various international restructurings of organizations.Close
to be announced.