On October 26, Washington, D.C. tax partner Eric Sensenbrenner participated in the panel “Restructuring Multinational Groups” during PLI’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2023. The speakers 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.
Skadden, Arps, Slate, Meagher & Flom LLP and Affiliates