Armanino LLP Welcomes You To Today s Webinar: International Tax: Trends, Risks and Opportunities
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1 Armanino LLP Welcomes You To Today s Webinar: International Tax: Trends, Risks and Opportunities The presentation will begin in a few moments Participants will receive an within 3 business days with access to their certificate of completion. 1 Armanino LLP amllp.com Armanino LLP amllp.com
2 About the Presenters Kevin A. Wise, CPA, Partner International Tax He specializes in U.S. international tax matters for the Technology and Financial Industries: Bachelor of Business Administration and Masters of Taxation University of Wisconsin Over 20 years of experience His practice includes consulting with multinational corporations on tax matters related to international expansion including; Offshore IP planning, financing, M&A, and corporate structuring 2 Armanino LLP amllp.com
3 About the Presenters Jon Davies, CPA, Partner International Tax He specialized in international tax structuring, cross-boarder transactions, transfer pricing, M&A integration. Bachelor of Science and Master s in Taxation from Brigham Young University 20 years of experience with 14 years at Big 4 Jon has a vast international network built on years of experience working with professionals around the world Helping technology companies successfully expand their operations worldwide 3 Armanino LLP amllp.com
4 Learning Objectives During today s webinar, participants will: Review the latest policies and discussions around base erosion and profit shifting Identify trends in choice of legal entities, intercompany relationships and related pricing considerations Examine several international structure alternatives Address how to optimize your global effective tax rates and minimize tax liabilities 4 Armanino LLP amllp.com
5 Presentation Overview Base Erosion and Profit Shifting The U.S. and OECD start to focus on aggressive profit shifting Transfer Pricing Why should your company care? Steps to implementing a transfer pricing policy International Tax Planning and IP Structure Planning benefits, considerations and requirements Choosing the right structure for optimum success Entity Choice 5 Armanino LLP amllp.com
6 Risks & Opportunities Risks Increased scrutiny of audits Local tax & regulatory environment Tax regime Opportunities 50%+ of tech companies rank international expansion as top investment priority Countries are motivated to offer tax incentives to businesses Incentives for businesses to reduce their tax rate Access to human capital 6 Armanino LLP amllp.com
7 Base Erosion and Profit Shifting 7 Armanino LLP amllp.com Armanino LLP amllp.com
8 Base Erosion and Profit Shifting (BEPS) OECD BEPS action plan Intended to address perceived abuses and flaws in global tax systems Key areas o Hybrid mismatch arrangements o CFC taxation o Excessive base erosion (earnings stripping) o Transfer pricing: intangibles value creation 8 Armanino LLP amllp.com
9 Base Erosion and Profit Shifting (BEPS) U.S. Proposals Obama Administration o The last four Obama Administration budgets have proposed anti-base erosion provisions Administration s Key proposals Excess returns on IP of CFCs 9 Armanino LLP amllp.com
10 Base Erosion and Profit Shifting (BEPS) Administration s Key proposals (continued) Anti-hybrid arrangements (2014) Tighten earnings stripping rules (2014) Broaden anti-inversion rules Ways and Means Proposals on taxing intangible income and a CFC minimum tax 10 Armanino LLP amllp.com
11 Transfer Pricing 11 Armanino LLP amllp.com Armanino LLP amllp.com
12 Transfer Pricing - Overview Transfer prices determine the amount of income (and tax paid) by country based on the prices charged for goods and services within the related group Tax authorities require that intercompany transactions comply with the Arm s-length standard Transfer pricing regulations control nearly all intercompany transactions: o Goods o Services o Licensing o Lending Arm s-length Standard Transfer prices between related parties should be the same as prices between unrelated parties 12 Armanino LLP amllp.com
13 Transfer Pricing Why Care? Need to justify intercompany prices to tax authorities Eliminate or mitigate transfer pricing penalties IRS agents are required to request transfer pricing documentation Loss companies affected through reduction of NOLs Critical to a successful offshore IP structure 13 Armanino LLP amllp.com
14 Transfer Pricing Steps to Implement Steps to Implementing a Transfer Pricing Policy Economic analysis of intercompany transactions (benchmarking) Documentation of policy Drafting the intercompany agreement Operational implementation (internal accounting, invoicing) Monitoring and update as necessary 14 Armanino LLP amllp.com
15 International Tax Planning and IP Structure 15 Armanino LLP amllp.com Armanino LLP amllp.com
16 International Tax Planning Benefits Non-US sales not subject to current US income tax Tax deferral and reduction in ETR Increased EPS Considerations Change in operations Increased compliance IRS scrutiny and challenge 16 Armanino LLP amllp.com
17 International Tax Planning (continued) Requirements Non-US sales infrastructure IT system modification/implementation Non-US contract negotiation and conclusion Non-US invoicing and support Other related non-us activities 17 Armanino LLP amllp.com
18 Developing the International Operating Structure R&D Company (US) Purchase Order From US Customers Sale of Products US Customers Contract Manufacturer (Country C) Company (Ireland) Royalty & Cost Share Payments Sales and Support Services Royalty Company (Cayman) Non-US Customers 18 Armanino LLP amllp.com
19 Developing an International Operating Structure Creation of an operating structure where as many of the following activities are conducted outside the U.S. Research and development (cost sharing) Procurement, contract manufacturing, test and assembly Sales solicitation and order acceptance Order fulfillment and post-sale services Invoicing and collections 19 Armanino LLP amllp.com
20 Entity Choice 20 Armanino LLP amllp.com Armanino LLP amllp.com
21 Entity Choice Considerations Contractor/Employee Representative office Branch Subsidiary 21 Armanino LLP amllp.com
22 In Conclusion During this webinar, we ve covered: The latest policies and discussions around base erosion and profit shifting Trends in choice of legal entities, intercompany relationships and related pricing considerations Why transfer pricing is important to your company Several international structural alternatives to optimize your global effective tax rates and minimize tax liabilities 22 Armanino LLP amllp.com
23 Armanino LLP Certified Public Accountants & Consultants Jon Davies, CPA phone: Kevin Wise, CPA phone: Participants will receive an within 3 business days with access to their certificate of completion. 23 Armanino LLP amllp.com Armanino LLP amllp.com
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