What’s trending in North American tax?

“During the client round table session, there was unanimous consent that tax reform has positively impacted the business environment for all companies across the middle market and beyond,” noted Steve Amigone, Chair of the Praxity Global International Tax Working Group. From listening to clients, Steve was encouraged to hear that they will rely increasingly on global service offerings coordinated through Praxity and the Alliance’s Participant firms in the future.

Concurring, Kellie Becker reaffirmed that the next 12 months will continue to bring new rules on the implementation of tax reforms, which clients will have to figure out how to best implement with their tax advisors.

Kellie explains: “All of these unknowns are keeping business leaders awake at night and they are nervous about timing their decision. They don’t want to act too swiftly, but are equally worried about the implications of leaving their decisions too late.”

Other conversations strongly indicated that clients seek proactive communications on topical initiatives, strong coordination across multiple service lines rather than working in silos, and that they expect firms to continue investing in new, innovative ways of working.

In the last 12 months, tax reform has completely reshaped how entities were going to be taxed in the U.S. Given the 21% tax rate, the US has become an attractive location for investment, highlights Steve.

“From a transfer pricing perspective and as we look to maximize benefits through the increase of income into the U.S., many of the ‘old rules’ for U.S. multinationals have been flipped on their head,” comments Steve. “We also see added benefits through increasing Foreign Derived Intangible Income (FDII) or reducing Global Intangible Low Taxed Income (GILTI) attributable to Controlled Foreign Companies (CFCs).

Entity structuring from a global perspective is another growing trend emerging in the U.S. following the tax reforms, with a number of entities seeking guidance.

“What’s clearly evident is there’s no One Size Fits All approach to tax and transfer pricing planning,” adds Steve. “Rather, the opportunities are driven through a detailed assessment of client’s fact patters.”

Other hot topics of discussion to emerge from the new tax regime included the new Base Erosion and Anti-abuse Tax. BEAT is especially punitive for larger multi-national corporations that are paying excessive amounts to foreign related parties for services (excluding cost of goods), highlights Steve. “While certain planning can be implemented to mitigate this risk, tax practitioners are carefully reviewing how best to navigate the new rules,” he says.

Three clients and two attorneys provided additional weight and an external perspective to the presentations. Feedback was extremely positive, with delegates commenting - “Of the moment course content... thoughtful and topical," to “If your business is expanding internationally, don't miss this conference.”

As with previous years, a wealth of content was shared. Seminars were structured to offer up to 15-hours of Continuing Professional Education (CPE) accreditation to all three target groups - newcomers, experts and industry pros.

Commenting on how sessions were structured to accommodate such a large volume of delegates with diverse knowledge, International Tax Partner at Mazars, Cormac Kelleher says: “The split of the event between different learning streams is ideal for someone seeking to acquire insight into different topics, all the while acquiring more detailed knowledge on speciality topics more relevant to them. Learning is not limited to the formal sessions. The blending of networking sessions throughout the event facilitates further opportunity to glean knowledge from industry and professional experts.

“Praxity Conferences are unlike other conferences in how they are structured. The focus is not on sitting mutely in a room for hours on end being fed information. Rather, there is a mix of technical and personal development content. Participant engagement is actively encouraged. All this leads to a more engaging event.”

“The NA International Tax Conference is structured for considerable CPE and people do go for that reason,” explains Kathryn Byrne, New York City-based Practice Leader of Manufacturing and Distribution for Mazars USA and member of the Nominating Committee of the International Federation of Accountants (IFAC). “We are a continuous learning profession. We need to continue to be learning.”

For Steffen Ahrens, a Partner at German firm FALK GmbH & Co KG, these Praxity conferences, including the NA Tax Conference provide the ideal means to collect CPE credits and bring him up to the professional level required.

“If you are visiting a conference it often comes in handy that there is the opportunity to earn credits, especially for those like me who have to earn credits not only to keep their local professional title, but also to fulfill the CPE requirements of a US CPA,” Steffen says.

In addition to CPE credits, Andrew Lam, National Director of Core International Tax, from MNP explains that as a Canadian tax advisor focusing exclusively on cross-border tax matters, “the NA International Tax Conference enables me to keep abreast of important U.S. and international tax developments. It is a great forum for us to network with clients and Praxity colleagues and to update them on Canadian tax opportunities and developments. Plus, they’re a fun group of people to be around."

Summing up, Steve reinforces the benefits of this annual event, which has grown popularity year-on-year. He says: “We continually track the investment and monitor the referrals that come out of this conference. For repeat attendees, it is regarded as an excellent platform for bringing together clients and global service providers to discuss relevant business topics.”