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April 7, 2016

As part of an ongoing Executive Roundtable Series, CBIZ MHM Memphis hosted a breakfast seminar last week focused on International Tax.  This session covered an array of international tax topics including proposed government regulations, outbound planning (hybrids, treaties, etc.), and base erosion & profit sharing (BEPS) reports.

With a room full of tax executives eager to gain knowledge on international tax trends, Don Reiser, Managing Director for CBIZ & MHM’s National Tax Office, began discussing the proposed Section 367(d) regulations and the effective government concerns and definition of tangible/intangible property.  Furthermore, Don educated attendees on the evolving permanent establishment (PE) issues as well as hybrid entity structures and multiple examples of offshore IP transfers.

In closing, Josh Finfrock, Director of Transfer Pricing for the Memphis Office, reviewed the impact of BEPS final reports as well as transfer pricing documentation and country-by-country reporting (CBCR).  Josh outlined in detail BEPS Action 13, which presents a 3-step approach to transfer pricing compliance including: a master file, local file, and CBCR details.

To attend one of our future seminars, join our mailing list by clicking here.  For questions regarding the topics and/or your company's international operations or practices, please contact Josh Finfrock at jfinfrock@cbiz.com or 901-685-5575.




January 27, 2016

Josh Finfrock, Director in the Memphis Office, recently authored an article covering the 2015 Fourth Quarter Update on Transfer Pricing.

Referencing his previous post, Josh begins by providing an update on the final BEPS project recommendations.  He then provided a United States transfer pricing update regarding proposed regulations released by the IRS and Treasury Department.

Josh’s article also gives detailed transfer pricing updates in foreign markets.  The recently issued updates concerning transfer pricing documentation and CbC reporting involved Australia, India, and Denmark.

For questions on how these transfer pricing updates may have an impact on your company, please contact Josh Finfrock at jfinfrock@cbiz.com or 901-685-5575.  To view the full article on CBIZ’s Insights & Resources page, click the button below.





November 10, 2015

Josh Finfrock, Director of the Memphis Office recently authored an article covering the Base Erosion and Profit Sharing (BEPS) recommendations.

On October 5, 2015, the Organisation for Economic Co-operation and Development (OECD) presented final recommendations relating to the BEPS project to the G20 Finance Ministers. The recommendations represent a multi-year focus on international tax policy aimed at curbing tax avoidance by multinational enterprises (MNEs) and include more than 1,600 pages covering 15 action points.

Josh’s article gives detailed insight into each of the 15 action points and summarizes key topics and recommendations presented by the OECD.

For questions on how these recommendations may have an impact on your company, please contact Josh Finfrock at jfinfrock@cbiz.com or 901-685-5575.  To view the full article on CBIZ’s Insights & Resources, click the button below.




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