Emerging Trends and Developments on GILTI, FDII and BEPS: Significant Strategies to Mitigate Risks and Pitfalls
The international tax landscape is expected to dramatically change before 2019 ends as developing countries consider a new global tax system and as the Tax Cuts and Jobs Act (TCJA) moves closer towards full implementation. Recent developments that should give us a glimpse of the future include the final set of global intangible low-taxed income (GILTI) regulations, the newly proposed foreign-derived intangible income (FDII) rules, and the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) program which aims to address “the tax challenges arising from the digitalisation of the economy.”
U.S. companies should revisit their tax strategies to cope with the looming changes.
Join a panel of key thought leaders and practitioners assembled by The Knowledge Group as they delve into an in-depth analysis of the current and emerging trends and developments surrounding GILTI, FDII, and BEPS enforcement. Speakers will also offer helpful insights on how to develop and implement effective strategies to mitigate risks and pitfalls and ensure compliance in this evolving regulatory climate.
In a LIVE Webcast, the speakers will discuss:
- Recent Trends and Developments :
- Potential Opportunities for U.S. Companies
- Addressing Risks and Pitfalls
- Tax Strategies
- Best Compliance Practices
Justin Kuczmarski, MBA, CPA, CVA, CEIV, ABV, President
NAV Valuation & Advisory LLC
James Guadiana, Partner
GILTI and FDII: Two Years Later
- Are the Carrot and the Stick Functioning Properly
- Companies shifting tangible assets abroad
- Studies have found evidence that firms with high pre-TCJA repatriation costs have an increase in foreign, rather than domestic, capital expenditures.
- Kenan Institute Study
- SEC Disclosure Analysis
- States Tackling GILTO and FDII
- Good examples: clear rules for income inclusion and deduction
- Bad Examples: unclear rules
- Mixed Results
Who Should Attend:
- Tax Attorneys
- Tax Executives
- Tax Directors
- Tax Consultants
- Finance Executives
Jim Guadiana focuses his practice on the tax aspects of domestic and international transactions and investments. He serves as advisor to public and privately-held multinational companies and investment firms with regard to their operations and investments in the United States. Jim also has extensive experience as tax advisor to a number of public corporations listed on the London, Hong Kong, and Toronto stock exchanges. Jim is respected domestically and internationally for his ability to identify and resolve unique and complex tax issues in domestic and cross-border investments in a myriad of fields. Jim also has represented clients before U.S. tax agencies and U.S. tax courts.
Jim routinely advises clients on the establishment of transfer pricing policies, and assists clients in implementing beneficial cost-sharing and other arrangements. He counsels public and private companies on preservation of net operating losses and provides planning on various cross-border sales of physical commodities and related hedging transactions. Jim instructs issuers and investment banks regarding the treatment of foreign corporations as to their status, or avoidance of status, as passive foreign investment companies (“PFICs”). He structures multinational executive compensation programs to achieve optimum tax benefits for employers and employees in multiple jurisdictions. Jim advises clients on the tax aspects of transfers of proprietary technology, including patents. He counsels multinational families with regard to their global investments, business activities and U.S. tax compliance requirements.
Jim Guadiana focuses his practice on the tax aspects of domestic and international transactions and investments. He serves as advisor …
Mr. Justin Kuczmarski, MBA, CPA, CVA, CIRA, ABV, CFF, is the President of NAV Valuation & Advisory LLC (“NAV”). Prior to founding NAV, Mr. Kuczmarski served as a NYC Practice Leader in Financial Advisory Services for a top 10 accounting and advisory firm. He also has senior M&A investment banking experience as a Valuation Practice Leader for a leading M&A boutique bank.
In 2016, Mr. Kuczmarski was a recipient of the NACVA 40 Under 40 from the nation's leading valuation association, the National Association of Certified Valuation Analysts (NACVA). Mr. Kuczmarski is the sole author of the 300-page guidebook entitled The Executive’s Guide to Business Valuation: Essentials for Advisors and Business Owners.
Mr. Kuczmarski received a B.A. in Politics from Princeton University. He also received an dual MBA in both Finance and Professional Accountancy from Fordham University's Gabelli School of Business in both Finance and Professional Accountancy, where attended on an academic fellowship in both departments.
Mr. Justin Kuczmarski, MBA, CPA, CVA, CIRA, ABV, CFF, is the President of NAV Valuation & Advisory LLC (“NAV”). Prior …
Print and review course materials
Method of Presentation:
On-demand Webcast; Group-Internet Based
General knowledge of tax laws
NY Category of CLE Credit:
Areas of Professional Practice
NASBA Field of Study:
Taxes - Technical
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