Local Office Blogs

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January 27, 2017

It is with great pleasure that CBIZ MHM Memphis announces that four employees have been promoted to Managing Director.

“On behalf of everyone at CBIZ MHM, I would like to congratulate each of our new managing directors in the Memphis office.  I am extremely proud of what this year’s class means to CBIZ MHM,” said Eustis Corrigan, Senior Managing Director, CBIZ MHM.

Brooke Balducci, CPA

  • Specialty: Corporate Tax Compliance and Consulting, State and Local Taxation, Passthrough Taxation, Accounting for Income Taxes
  • Organizations: AICPA, TSCPA, Mid-South Food Bank
  • Education: Mississippi State University
  • Best Advice Brooke Has Ever Been Given: "Do your best even when no one is watching."

Cherry Blanton, CPA

  • Specialty: Financial Statement Audits, Employee Benefit Plan Audits, Privately Held Companies
  • Organizations: AICPA, TSCPA, Memphis Institute for Leadership Education (MILE), Department of Management in Fogelman College of Business at University of Memphis
  • Education: Faulkner University
  • Best Advice Cherry Has Ever Been Given: "You can be anything you want to be."

Rhett Butler, CPA

  • Specialty: Financial Statement Audits, Transaction Advisory, Fraud and Anti-Corruption Services, Acquisition Due Diligence, Manufacturing
  • Organizations: AICPA, TSCPA, Association of Certified Fraud Examiners
  • Education: Rhodes College
  • Best Advice Rhett Has Ever Been Given: "Pursue perfection and accept excellence."

Josh Finfrock

  • Specialty: Transfer Pricing, Development of Planning and Documentation Strategies for Multinational Corporations
  • Education: Wheaton College
  • Best Advice Josh Has Ever Been Given: "You're a problem solver. You will be able to figure this out on your own."

“We are adding 4 strong managing directors with diverse voices and deep industry experience to our leadership team.  We are also promoting leaders we have developed ourselves and who represent the culmination of hard work, focus and passion,” Corrigan said.  “This accomplished group embodies the mission and values we live every day at CBIZ MHM and has exhibited an extraordinary ability to create value for our clients, firm, profession and communities.  The promotion of these new managing directors further ensures that we are prepared for the ever changing environment and highlights our commitment to building a high-performance culture.”

For more information about our team in Memphis, click here.

August 24, 2016

Josh Finfrock, Director in the Memphis Office, recently contributed to an article covering updates on 2016 Second Quarter Transfer Pricing Developments.

The article discusses the recently released guidance from the Australian Tax Office (ATO), the recent court ruling in favor of Medtronic, and new guidance from the OECD on the implementation of Country-by-Country reporting.

The Medtronic case is worth noting due to the tax the company would have paid had there been an alternate conclusion. Medtronic recently received a favorable ruling from the U.S. Tax Court in its transfer pricing dispute with the IRS. Had they received an unfavorable ruling, Medtronic would have owed nearly $1.4 billion. The issue arose because the IRS argued that Medtronic U.S. should have received higher royalty rates from its Puerto Rico based subsidiary, MPROC. Medtronic argued that the IRS did not adequately consider the importance of product quality in the medical device industry, and that MPROC provided more than just product assembly.

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 here.

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.

March 4, 2016

Over the next six months, the Memphis office is focusing on different specialties and services by featuring a Q & A with one of our local experts each month.

Josh Finfrock serves as a Director and leads the transfer pricing practice for CBIZ & MHM Memphis.  Josh has significant experience providing guidance on the development of internal transfer pricing policies and on the development of planning and documentation strategies for multinational clients operating in various countries worldwide.

Not only does this series allow you to get to know Josh on a more personal level, but he also answers important questions like “What should be in consideration as you're doing business internationally?”  The conversation continues with Josh discussing the common issues he finds, consequences of companies not in compliance, and why it’s important for transfer pricing to be controlled and monitored.

More resources featured on Josh’s Conversation page include previously featured articles, a BizTip Transfer Pricing video, and information on the latest CBIZ MHM Executive Roundtable Series.

Read the full conversation by clicking here.

February 26, 2016

Josh Finfrock, Director in the CBIZ MHM Memphis office, recently spoke at the U.S. Intermediate Transfer Pricing Update Bloomberg BNA conference on February 22nd & 23rd.

The two-day conference included instruction on common transfer pricing methodologies and concepts for accountants, attorneys, and other tax practitioners.  The program was designed as a training session to introduce tax practitioners to the key reporting and compliance issues in establishing an arm’s length price under Sec. 482 and the OECD guidelines.

Finfrock leads the Transfer Pricing practice at CBIZ and performs work for companies all across the world.  At the conference, Josh presented 'Analyzing the Intercompany Transfers of Tangible Property.'  In this session, he discussed… available methodologies, types of manufacturers, types of distributors, and examples of common intercompany transactions as it all relates to sales of tangible property.

Transfer pricing in the United States continues to be a topic of major concern to tax executives at U.S. outbound and inbound multinationals. Transfer pricing requires financial statement results to properly reflect profits between business units for tax and earnings forecasts. As a result, corporate tax and financial executives must establish effective internal controls and defend their pricing policies before their auditors and the IRS.

For questions regarding transfer pricing and its impact on your international operations, 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.

October 6, 2015

The Organisation for Economic Co-operation and Development (OECD) and the G20 Countries continue to release and finalize the remaining deliverables of their 15-Point Action Plan addressing the Base Erosion and Profit Shifting (BEPS) project. As discussed in one of our earlier insights on the topic, transfer pricing documentation is being re-examined in an effort to enhance transparency, certainty, and predictability for both tax administrators and taxpayers. Adoption of the new guidance is being evaluated by many taxing authorities worldwide in which multi-national enterprises do business.

The following list highlights some of the countries that have recently issued updates and developments from across the globe concerning transfer pricing documentation and regulations:

Mexico presented its Congress with a tax reform package for review on September 8, 2015. The package envisions the adoption of BEPS action item 13 relating to country by country reporting (CBCR), master file, and local file reporting requirements. The requirements would be introduced on a calendar year basis with the first due on December 31, 2017 for the tax year ending December 31, 2016. Multinationals with local revenue of approximately $38 million USD would be subject to master file and local file requirements while Mexican owned multinationals with group revenue of approximately $714 million USD would be subject to CBCR.

Australia has released draft transfer pricing legislation which would require a country-by-country report in addition to the master file and the local file in part of compliance with Action 13 (Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting). Multinationals headquartered in Australia with group revenues of A$ 1 billion or more will be required to file a country-by-country report in Australia. Multinationals headquartered outside of Australia above the same threshold will be required to prepare Master File and Local File documentation. 

Spain has released new transfer pricing guidance which now requires a country-by-country report in addition to the master file and the local file in part of compliance with Action 13 (Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting). Spain reacted quickly to implement recommendations stemming from the work of the OECD’s BEPS project. The guidance would be applicable for multinationals with group revenue of greater than €750 million headquartered in Spain with the first report due within 12 months of the first tax year ending after January 1, 2016.

Earlier this spring, the Ministry of Finance published a draft Royal Decree approving the Corporate Income Tax Regulations.

In February, the Canada Revenue Agency (CRA) released guidance following the OECD’s BEPS project guidelines. Guidance issued included policies on internal audits of intra-group services and the use of multiple year data in transfer pricing analyses. Intra-group services will be deductible only if the services confer genuine benefit or economic value to the recipient.

If your company operates within any of these countries or has questions regarding the continued changing transfer pricing environment worldwide, please reach out to your local CBIZ contact to make sure your documentation will be sufficient to manage risk associated with transfer pricing.

Any outbound payments to overseas related parties will be overseen by the Chinese tax authority as documented in Public Notice 16 to ensure authenticity and adherence to the arm’s length standard. This notice is a direct result of China wanting to show their support for the BEPS initiatives.

Specifically, China is targeting services charges considered to be irrelevant for the Chinese taxpayers function and risk profile, services merely protecting shareholder interests, duplicative of services already paid for locally, services that are a result of passive association of the group or do not bring direct benefit, or services that are already remunerated through other intercompany transactions.

Draft amendments of the Personal Income Tax (PIT) and Corporate Income Tax (CIT) acts, which include new transfer pricing documentation requirements for Polish taxpayers, were released by Poland in May. Drafted requirements are similar to the BEPS initiative and will be more extensive than what is currently required. Amongst other updates, the deadline for preparing the documentation will be changed to reflect the current annual tax return deadline.

Bolivia has officially recognized the new transfer pricing guidelines defined by the OECD and will be enforcing said rules for affected taxpayers in the fiscal year 2015.

The Ministry of Finance introduced amendments to transfer pricing assessment rules and concepts reflected in the OECD guidelines in March of this year.

If you have further questions regarding transfer pricing regulations and updates, feel free to contact our local Transfer Pricing expert Josh Finfrock at jfinfrock@cbiz.com.

September 22, 2015

Although transfer pricing services are not as commonly known in the accounting industry, the work has an international reach that can have a major economic impact on companies big and small.

Josh Finfrock, Director in the Memphis Office is leading this niche, an essential division that focuses on international taxation.  Recently featured in an article published by The Daily News, Josh gives insight on his work, industry details, and personal experience.

“We’re helping companies on one end just starting to figure out how to expand internationally or maybe they are just coming to the U.S.,” he said. “They are trying to get their arms around what they have to do. But then we’re working with really established companies. They have a big international footprint with a significant amount of changes happening or compliance issues to make sure they are doing things right.”

For questions on transfer pricing’s impact on your company, please contact Josh Finfrock at jfinfrock@cbiz.com or 901-685-5575.  To view the full Memphis Daily News article, click the button below.

May 6, 2015

The Memphis office is proud to announce the selection of five of our employees, Brooke Balducci, Cherry Blanton, Rhett Butler, Josh Finfrock, and Karen Gondan (pictured below L-R), to the Emerging Managing Director Academy (EMDA), Class of 2017. Each brings a unique perspective regarding their journey to this point in their career.

  Brooke Balducci   Cherry Blanton  Rhett Butler       

  • Brooke Balducci is a Senior Manager in our tax services practice. Her prior Big 4 experience coupled with insight gained during her six years with us have greatly contributed to her expertise with large complex clients that are publicly traded or owned by large private equity groups.
  • Cherry Blanton, an audit Senior Manager, currently serves attest clients in a wide variety of industries with diverse types of owners ranging from private equity firms to family groups. Prior to public accounting, Cherry held corporate accounting positions with privately held companies in the airline and marine industries.
  • Rhett Butler joined our firm eight years ago after earning his Masters and currently serves as a Senior Manager in the attest practice. Rhett focuses primarily on mergers and acquisitions, fraud, and employee benefit plans in the areas of manufacturing, retail, and distribution.
  • Josh Finfrock is the Director of our Transfer Pricing practice in Memphis. He joined our firm in 2008 and also has prior experience with a Big 4 firm. Through Josh's leadership, we have been able to capitalize on the expanding market demand for this unique service line.
  • Karen Gondan, a Managing Director in our attest practice, joined our firm about a year ago. Karen's participation in the EMDA program will not only be a way to further her understanding of MHM and CBIZ, but also will provide an opportunity for her to share her prior partner level experiences with those beginning that career path.
The Emerging Managing Director Academy's goal is to make sure that newly promoted Managing Directors make the best possible start in their new role.  This program helps them achieve a higher level of self-awareness and self-development, combined with relevant business, people development, and leadership skills. 

Congratulations to Brooke, Cherry, Rhett, Josh, and Karen! We look forward to seeing them build upon the existing qualities and capabilities that got them to this point in their respective careers.


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