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 email@example.com or 901-685-5575.