On Dec. 15, 2022, Partner Brian Davis took part in the “Cross-Border Financing” panel discussion at the IRS/George Washington University Law School’s Institute on Current Issues in International Taxation. Davis and his co-panelists focused on how U.S. and non-U.S. multinational companies should consider structuring external and internal financing in light of myriad changes to tax law.
Topics included 163(j) interest deductibility limitations, base erosion and anti-abuse tax (BEAT) exposure from related party debt, and the potential impact of the new 15% corporate alternative minimum tax in financing assessments, among others.
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