Overview
Caroline Ngo (USIT-DC) will speak at the Practicing Law Institute’s 2020 Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings virtual program on October 15, 2020. Ngo will be a co-presenter in the “Restructuring Multinational Groups” session, which will cover the following: cross-border structuring issues and the impact of global intangible low tax income (GILTI), foreign-derived intangible income (FDII), base erosion and anti-abuse tax (BEAT), Section 163(j) and anti-hybrid rules on the location of third-party and intercompany financing arrangements, tangible and intangible asset ownership, and intercompany service and contract arrangements.
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