PLI’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2026 New York City

Caroline Ngo spoke at PLI’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2026 New York City. She spoke on the following panel:

Restructuring Multinational Groups
Wednesday, October 21 | 4:30 pm

This session will discuss cross-border structuring issues and the impact of the net CFC tested income (NCTI), foreign-derived deduction eligible income (FDDEI), 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. After completing this session, participants will be able to:

• Create a foreign entity and financing structure that facilitates repatriation and use of tax attributes
• Apply the international tax provisions, such as NCTI, FDDEI, BEAT, and 163(j), to compute U.S. taxable income
• Understand the impact of new legislation, regulations, and other guidance on group restructurings and other internal transactions

Learn more here.