This topic will cover not only what is necessary to comply with the multinational thin capitalization rules but also how it is possible optimize a MNO’s structure from a capitalization standpoint in light of the thin capitalization rules. We will cover the background of thin capitalization, how it is possible to resolve thin capitalization issues and walk through a number of illustrative examples.
Agenda
Faculty
John P. Garcia, CPA, M.B.A.
Corporate Tax Advisors
- More than 25 years of experience providing services to major multinational corporations such as Billabong, Nixon, Targus, Marriott, Dial, Henkel, The University of Phoenix, and CPE, Inc
- Conducts regular seminars and workshops on the following: Tax Aspects of the CARES Act, Accounting for Income Taxes – ASC 740/FAS 109; International Taxation; State and Local Taxation; and Uncertain Tax Positions – FIN 48 and Transfer Pricing
- Wrote the SRR Journal, Fall 2016, How to Properly Capitalize Subsidiaries Without Getting Ensnared in the Earnings-Stripping Rules; California CPA magazine, June 2013, An Integrated Database Solution to Global Withholding Compliance; and Thomson Reuters, Corporate Taxation, December 2009, Green Corporate Tax Incentives-Wind Technologies
- Member of Arizona Society of CPAs and AICPA
- M.B.A. degree in international business; B.S. degree in accounting and finance, University of Maryland College Park
- Can be contacted at 877-728-1400 or [email protected]
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