Total Credits: 4 including 4 Taxes - Technical
The international aspects of 2017’s Tax Cuts and Jobs Act legislation are more than a little intricate and we unpack how it affects businesses along with other tax items from transfer pricing to the repatriation of U.S. funds.
The Impact of BEPS on Transfer Pricing
World Finance reported that around 60 percent of international trade happens within multinationals and so transfer pricing is merely a way of life for these companies and subsidiaries. With this in mind, Country-by-Country Reporting (CbCR), part of OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan 13, is set to be a significant development surrounding annual returns. Paired with CbCR, BEPS also suggests utilizing a master file and local file. Bring in for scrutiny principles that are usually held at arm’s length. This session discusses the implementation and reporting requirements in a post BEPS environment. Learn how to successfully manage your Global TP Documentation.
Donna R. Frye, CPA – Director of Transfer Pricing Services, UHY Advisors, Detroit
U.S. Tax Reform and Its Aftershocks
Tax reform has altered the face of international business through both planned changes and unintended consequences. Explore what clients are already struggling with during these restructuring efforts and gain a clear understanding of the new base erosion and anti-abuse tax (BEAT) and global intangible low-taxed income (GILTI), and foreign-derived intangible income (FDII).
Scott F. Hesse, CPA – International Tax Partner, PwC, Detroit
Craig R. Riffel, CPA – International Tax Manager, PwC, Detroit
Tax Issues in Canada
With the Tax Cuts and Jobs Act casting a constant spotlight on the taxes within our country, it is far too easy to miss important changes and updates taking place around the world. In addition to the US changes on international business, 2017 also saw major changes in Canadian tax law. In this session we discuss Canadian-specific income and sales tax issues, as well as foreign reporting requirements, so you can manage the effects on you and your cross-border clients.
Edwin B. Miles, CPA, CA (Ontario) – Tax Partner, MCO Partners PC, Windsor, ON, Canada
Return to Sender: How to Bring Money Back into the U.S.
As of 2016, there was roughly $2.5 trillion in American companies’ funds being housed overseas, according to Capital Economics. The hesitation to bring this money home, where it can best benefit our economy, lies in our staggering corporate tax rate of 35 percent. How reform addresses the repatriation of funds is a large issue. Join us as we address it with a China- specific case study.
C. Peter Theut – Founder & CEO, Global Bridges Network, China Bridge, Global Community Outreach, Ann Arbor
Important CPE Credit Information_READ BEFORE WEBCAST UPDATED (0.47 MB) | Available after Purchase |
International Practice Morning Workshop: International Tax slides (2.87 MB) | 62 Pages | Available after Purchase |
Donna is the director of transfer pricing at UHY Advisors. Donna is a seasoned professional with over 16 years of transfer pricing knowledge including international tax and transfer pricing compliance, planning and controversy services. As director of transfer pricing, Donna works as part of the international tax services practice assisting with transfer pricing planning, benchmark analysis, implementation, BEPS issues, documentation and controversial work with respect to transfer pricing. She has over 16 years of transfer pricing knowledge, including Big 4 accounting experience and Big 3 automotive experience. She is a licensed CPA in the state of Michigan and double alumni of Walsh College.
Scott, an International Tax Services Partner, leads the Global Structuring Practice for PwC’s Midwest market and has 26 years of experience specializing in all phases of U.S. and international taxation. In assisting clients to minimize their global tax burden, Scott has worked with both "inbound" and "outbound" client companies to address transfer pricing issues, organizational restructuring options, Intangible Property structuring alternatives, repatriation planning strategies (including dividends, royalties, management fees, etc.), earnings and profits studies, subpart F income analyses and foreign tax credit utilization issues.
Scott also has extensive experience in supporting the merger and acquisition activities of his clients, including completing buy-side tax due diligence reviews in connection with domestic and international transactions; identifying structuring options for both taxable and tax-free transactions; reviewing and implementing cross-border financing strategies; and providing structuring advice and implementation assistance for post-deal integration.
Scott is a graduate from the University of Michigan where he received his Bachelor of Business Administration. Scott is professionally affiliated with the AICPA, MICPA and the International Fiscal Assocation.
Craig, an International Tax Services Manager, has 8 years of experience focused on U.S. international taxation. Craig has extensive experience with both “inbound” and “outbound” client companies and has worked with them to address cross-border legal entity restructuring opportunities, cross-border financing & large-scale repatriation strategies, post-deal integration, foreign tax credit optimization, subpart F income analyses, foreign income tax reporting for US multinationals, and ASC 740 tax accounting.
Craig also has extensive experience in designing and implementing tax-efficient global structures that include holding and finance company planning, as well as intellectual property planning.
Craig is a graduate from Michigan State University where he received his BA in Accounting and his MS in Accounting.
With over 20 years in public accounting, Ed founded MCO Partners, PC, in 2001, with a focus on Canadian and U.S. taxation. Recognized as a local expert, Ed recently completed his term as Chairman of the B.O.D. of the Windsor-Essex Regional Chamber of Commerce. Ed is a C.A. licensed in Ontario, a licensed C.P.A. in Michigan, and a member of the Michigan Institute of C.P.A.’s.
C. Peter Theut also is the Founder of Global Bridges Network and Global Community Outreach, a non-profit organization. Global Community Outreach functions in coordination with various Non-Governmental Organizations worldwide to provide humanitarian assistance to needy parts of the world, with particular focus on remote parts of Africa, China, and Mexico. Global Bridges Network was founded by Theut to expand the China Bridge business model to selected Countries and selected Industries. To date the successful China-focused business model has been expanded geographically to include Korea Bridge, Mexico Bridge, Russia Bridge, Japan Bridge, Africa Bridge, Scandinavian Bridge and South American Bridge.
Business Professionals' Network, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org
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