Understanding the Newly Issued Proposed Regulations under §385

385 copy.jpg
385 copy.jpg

Understanding the Newly Issued Proposed Regulations under §385

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This webinar will cover the full reach of the Proposed Regulations under Section 1.385 that have a far reaching impact.  We will also address ways companies can stay in front of the impact of these proposed regulations.

The panel will discuss the following:

  • Overview of the proposed regulations
  • Definition of an “expanded group” and its implications
  • Impact on intergroup lending — inbound and outbound
  • Impact on intergroup cash pooling — inbound and outbound
  • Importance of documentation
  • New rules

Presented by:

Greg Bryant is a lawyer and certified public accountant with over 25 years of experience as a Big 4 National Tax Director and as VP of Taxes and Shared Services for a Fortune 1000 multinational. Prior to founding BILTgroup, Greg was most recently a Partner and Chair of International Tax at Williams Mullen. Having worked hands-on in many areas of international taxation, law and accounting both as an executive in a Fortune 1000 company and as a legal and tax advisor, Greg provides in-depth tax planning assistance to companies that are expanding into new markets and confronting complex transfer pricing, structuring and tax accounting issues. He answers the “how to” questions. As Outside Corporate Counsel for several multinational clients, he has negotiated, drafted and deployed multinational supply chain framework agreements, structured international supply chain networks, and leveraged the value chain of companies to reduce tax risk and improve cashflow. He has represented companies in many US and non-US tax controversies, including tax litigation cases in Holland and Germany. Greg earned his accounting and Juris Doctor degrees from the University of South Carolina. He has his LLM in Taxation from Georgetown University Law Center. He is licensed as a Certified Public Accountant in Maryland and North Carolina, and is a licensed attorney in Pennsylvania. Greg is a member of the American Institute of Certified Public Accountants (AICPA) and International Fiscal Association (IFA). Greg is also a Regional Vice President of IFA and a founding member of the Triangle IFA chapter. His law practice is entirely international and federal law.

Ted Brooks has over 20 years of public company, private company and law firm experience developing strategic tax planning initiatives for businesses and investors, including international corporate treasury centers, intellectual property development structures, hedge funds, asset management vehicles, joint ventures, structured financings and complex M&A transactions. He specializes in both U.S. and non-U.S. tax laws and is a frequent speaker on U.S., international and cross-border taxation. In 2011, Mr. Brooks successfully launched the U.S. affiliate office of Weidema van Tol, Attorneys & Tax Advisors, an international law firm with offices in Luxembourg, Switzerland, the Netherlands & Washington DC. Previously, Mr. Brooks was Vice President of Tax and General Tax Counsel for ContourGlobal, a company that develops, acquires and operates conventional and renewable power and energy companies around the globe. With solar, wind, hydroelectric, biomass and tri-gen facilities in the U.S., Europe, Latin America and Africa, Ted was formerly Vice President, International Tax and Global Tax Counsel for Marriott International, a leading hospitality and lodging company with more than 3,000 properties in the U.S. and 67 other countries and territories around the world. Earlier in his career, Mr. Brooks was an associate within the Tax Practice Group at the Washington D.C. law firm of Sutherland Asbill & Brennan LLP. Mr. Brooks is a member of the District of Columbia Bar and is admitted to practice before the U.S. Tax Court. He is a member of the D.C. Bar Tax Section, the American Bar Association and the ABA Tax Section. He received a Masters of Law degree in Tax from the Frederic G. Levin College of Law at the University of Florida, a Juris Doctor degree from the Delaware Law School and a B.B.A. degree in International Finance from the University of Miami (FL).