Overview
Brian H. Jenn was a speaker at the Practising Law Institute (PLI) event, “Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2023 Chicago” on November 15 – 17, 2023. Brian’s session, “Restructuring Multinational Groups,” discussed cross-border structuring issues and the impact of the global intangible low-taxed income (“GILTI”), foreign-derived intangible income (“FDII”), base erosion anti-abuse tax (“BEAT”), Section 163(j) and anti-hybrid rules, as well as pending legislative and international proposals, the location of third-party and intercompany financing arrangements, tangible and intangible asset ownership, and intercompany service and contract arrangements.
