Overview
Caroline H. Ngo and Richard C. Call were speakers at the Practising Law Institute (PLI) event, “Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2023 New York” on October 25–27, 2023.
Caroline’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.
Richard’s session, “State and Local Tax Issues in Corporate M&A Transactions,” examined the state and local tax issues that arise in corporate transactions and tax-free reorganizations. The panel discussed how to avoid common traps when evaluating whether a transaction is income “tax free” for state and local tax purposes, reviewed real estate transactions to determine transfer tax liability and covered common issues with state tax due diligence.