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Chip Morgan Ingrid Gardner Jerry Seade Malcolm Joy INTERNATIONAL TAX STRUCTURING 1 MARCH 2016
Chip MorganIngrid GardnerJerry SeadeMalcolm Joy
INTERNATIONAL TAX STRUCTURING
1 MARCH 2016
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CPE AND SUPPORT
CPE PARTICIPATION AND REQUIREMENTS – TO RECEIVE A CPE CREDIT FOR THIS WEBCAST
You’ll need to actively participate throughout the program.
Be responsive to at least 75% of the polling questions. Please note, the polling questions will not be announced, but will appear on the right-hand-side of your screen throughout the presentation.
CERTIFICATE OF ATTENDANCE If you are logged in the entire time and respond
to all polling questions, you will be notified via email when your certificate is available.
CONTACT Please email [email protected] with
any queries.
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PRESENTERS
Chip MorganInternational Tax PartnerUS
Malcolm JoyInternational Tax PartnerUK
Jerry SeadeInternational Tax PartnerUS
Ingrid GardnerInternational Tax Managing DirectorUK/US Tax Desk
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INTERNATIONAL TAX STRUCTURINGFirst Venture into Overseas Markets
Delivery of:• Products
• Services
• Intangibles
Taxes• Income and Withholding
• VAT
• Payroll/Social Security Contribution
Local Country Presence• None
• Rep Office
• Permanent Establishment
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INTERNATIONAL TAX STRUCTURING
Operational vs Legal vs Tax Structure
Setting Up More Tangible Presence Overseas
Following the Cash • Coupled with:
cash repatriation exit strategies
Tax Compliance
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INTERNATIONAL TAX STRUCTURING
What do we mean by IP?
Local Creation/Exploitation of IP
Where should IP be located?
• Commercial needs
• Substance!
Tax considerations
• Local incentives
• Exit issues
• CFC issues
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INTERNATIONAL TAX STRUCTURING
Substance and transparency
Wider Consideration of Value Chain Planning as Next Step from IP Migration
BEPS – transfer pricing issues
Changing tax laws
Central Entrepreneur
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INTERNATIONAL TAX STRUCTURING
Patent Box
Knowledge Box
R&D tax credits
Diverted Profits Tax
Incentives and Anti-avoidance Provisions
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INTERNATIONAL TAX STRUCTURING
Cost vs Benefit Analysis
Enhancing/supplementing vs Limiting Value Creation
Using Advance Agreements
Planning with the End Game in Mind
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INTERNATIONAL TAX STRUCTURING
Greater transparency as a result of BEPS
Specific UK rules
Public interest
Disclosure of Tax Strategy
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THANK YOU
CHIP [email protected] | +1 310 557 7517
INGRID [email protected] | +1 212 885 8268
JERRY [email protected] | +1 713 986 3108
MALCOLM [email protected] | +44 207 893 3718
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t: +1 310 557 7517e: [email protected]
CHIP MORGANPartner – International Tax | US
EXPERIENCE SUMMARYChip’s career has been centered on international tax for over 30 years. He has been an ITS partner with two of the Big 4, where he advised clients across a broad range of industries, geographies and transactions. In addition, he has industry experience as VP Tax for a semiconductor manufacturer and a software company, where he had practical experience with implementing and defending international tax structures, and working to keep the tax structures aligned with the underlying business operations as they evolve over time.
Chip has worked in New York, Brussels, San Jose and Los Angeles and has assisted companies ranging from startups to very large, mature enterprises. He has deep technical expertise, combined with practical hands on experience.Chip has studied accounting at the University of North Carolina and attended the Columbia Law School.
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t: +1 212 885 8268e: [email protected]
INGRID GARDNERManaging Director – International Tax | UK/US Tax Desk
EXPERIENCE SUMMARYIngrid is Managing Director UK/US Tax desk, based in New York. She has more than 20 years’ international tax experience working with UK and US multinational companies on cross border structuring, including: financing and IP planning; foreign tax credit management/repatriation planning; CFC planning; treaty planning; and value chain transformation. Prior to joining BDO, Ingrid was a principal in the value chain transformation practice of PwC US and prior to that, an international tax structuring partner in PwC UK.
Ingrid has a Master’s degree in taxation from Fordham University, New York and a Bachelor’s degree in economic & social studies from the University of Manchester, England. She is a fellow of the Institute of Chartered Accountants in England and Wales and also a member of the Chartered Institute of Tax in the UK.
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t: +1 713 986 3108e: [email protected]
JERRY SEADEPrincipal – International Tax | US
EXPERIENCE SUMMARYJerry is an international tax principal at BDO in the US. He has over 20 years experience serving mid to large multinational clients.
He specializes in advising clients on cross-border matters relating to mergers and acquisitions, joint ventures, offshore structures for intangibles, financing and services companies and outbound and inbound investments. He also has lead engagement teams on outsourcing of U.S. international tax reporting services for several multinational clients as well as assisted clients with transfer pricing and tax accounting (ASC 740) matters.
Jerry has degrees in business and law from the University of Texas at Austin and an LL.M. in Taxation from the University of Houston. Jerry is fluent in Spanish and is one of the leaders of BDO’s Latin America desk.
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t: +44 20 7893 3718e: [email protected]
MALCOLM JOYPartner – International Tax | UK
EXPERIENCE SUMMARYMalcolm is an international tax partner at BDO in the UK . He leads the Value Chain and Transfer Pricing team and specializes in advising UK and overseas owned businesses on international tax planning. Malcolm works closely with international tax teams around the world to deliver the most efficient tax structures to our clients. He is one of BDO’s UK/US liaison partners and is a key member of the international tax centre of excellence.
Malcolm has more than 20 years’ experience in advising businesses on tax compliance and advisory matters. His clients range from fast-growing privately owned businesses to major multinationals. Malcolm is particularly experienced in cross-border taxation between the UK and the US, intellectual property ownership and acquisition planning.
Malcolm has a UK degree in business studies and French and has studied at the Sorbonne in Paris. He is a member of the Institute of Chartered Accountants in England and Wales and also a member of the Chartered Institute of Tax in the UK.
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