BPM international tax specialists, Javier Salinas and Michael Santos are presenters at the 2018 LEA Spring North American Conference. Their presentation will cover the technical and financial modeling aspects of an actual BPM project involving a relatively complex client cross-border structure with numerous foreign entities of various types held 100% by an individual U.S. person, in some cases directly and in other cases through a U.S. S Corp.
The project included:
- Determination of transition tax liability
- Analysis and financial modeling of S Corp to C Corp conversion under new U.S. international tax provisions
- Analysis and financial modeling of CFC ownership directly, via S Corp and via C Corp under new U.S. international tax provisions
To learn more about the case study, contact Javier Salinas, Managing Director, International Tax Services, at email@example.com or (415) 288-6291. Learn more about BPM’s full range of International Tax and Transfer Pricing services by clicking here.