GILTI, FDII, and BEAT: Post Tax Reform Planning Ideas and Tools for Multinationals

05 June 2018
11:00 – 12:00 (EDT)
Webinar  -  On demand
Register here

This is a complimentary program sponsored by TMF Group.

This webinar will provide strategic planning ideas, service offerings and planning tools, with respect to International tax provisions of US Tax reform. Topics of discussion will include:

  • Deduction with respect to Foreign-Derived Foreign Intangible Income (“FDII”)
  • Global Intangible Low-Taxed Income (“GILTI”)
  • Base Erosion Alternative Minimum Tax (“BEAT”)

Considerations of international expansion, including

  • Movement of money
  • Global workforce
  • Administrative infrastructure

Educational Objectives

Key Takeaways – participants will gain an understanding of the following

  • How tax reform impacts IP valuations for inbound and outbound transfers
  • Different FDII and GILTI scenarios
  • When does IP migration or cost sharing still work
  • What we are seeing in the market

Who would benefit most from attending this program?

Attorney/Counsel, Controller/Comptroller, CPA/Accountant, CEO/President, General Counsel


Larry Harding - President Consultancy Solutions - TMF Group
Larry joined TMF Group in August 2017 as President of the new division, Consultancy Solutions. He joins after having founded and, as CEO of High Street Partners (HSP) since 2003. HSP went on to become an entrepreneurial success over the ensuing decade, ranking twice consecutively on the Inc 500 as one of the fastest growing companies (#84 and #79) in the US, and fundraising more than $20m in venture capital proceeds. The success of HSP saw Larry win EY’s prestigious Entrepreneur of the Year award for the Maryland region in 2013, and in the following year he managed the successful exit of the business as part of a private equity backed merger transaction. Previously he was Senior Audit Manager and M&A consultant with Ernst and Young in Boston, was CFO for several Boston area high tech companies, and served as VP of International Finance for CIENA Corporation.

Jason Gerlis - Regional Director, North America & Caribbean - TMF Group
Jason is responsible for TMF Group client delivery in the USA, Canada, BVI, Curacao and Cayman Islands where his teams support businesses expanding, or investing into the region. He is an experienced Corporate Director who regularly advises USA and Canadian businesses looking to expand abroad, as well as foreign companies and individuals coming to North America. Jason has been with TMF Group for four years, first based in London, but relocated to Miami, Florida in November 2014. Previously he worked at Deloitte Consulting LLP and Tesco PLC specialising in strategy, change management and Operating Model Development. Jason is a graduate of the University of Oxford and a Black Belt in Lean Six Sigma.

Maruti Narayan - Partner - DLA Piper, New York City
Maruti Narayan, Partner, DLA Piper, New York City advises US and foreign-based multinationals on a broad range of international tax matters, including supply chain structuring, IP migration, US income tax treaties and cross-border mergers and acquisitions.  Maruti earned a B.A. from Yale University and a J.D. from the University of Virginia School of Law.

Philip Rogers - Partner - DLA Piper, New York
Philip Rogers, Partner, DLA Piper, New York City has practiced international tax law since 1983 and concentrates his practice in international tax, including legal and operational structuring, general international tax planning matters, global transfer pricing strategy and documentation, cross-border mergers, acquisitions, dispositions and joint ventures, and international tax controversy. He has led dozens of international structuring projects for companies across a wide spectrum of industries and jurisdictions, and his clients include leaders in the financial, high technology and consumer products industries.

Before joining DLA Piper, Philip was with a Big 4 accounting firm, where he represented numerous Fortune 100 companies in their international tax planning, advising them on a broad range of cross-border issues, including international restructuring, post-merger and post-acquisition integration, repatriation planning, global supply chain planning and IP migration.


Continuing Education



Credits: COA, 1.2 CPE, 1.2 CLE

Practice Areas: Tax

Prerequisite: Basic knowledge of international tax laws.

Level: Intermediate