INTERNATIONAL TAX

STRUCTURING
Chip Morgan
Ingrid Gardner
Jerry Seade
Malcolm Joy

1 MARCH 2016
CPE AND SUPPORT

CPE PARTICIPATION AND REQUIREMENTS – TO CERTIFICATE OF ATTENDANCE

RECEIVE A CPE CREDIT FOR THIS WEBCAST
 You’ll need to actively participate throughout
the program.
 Be responsive to at least 75% of the polling
questions. Please note, the polling questions
will not be announced, but will appear on the
right-hand-side of your screen throughout the
presentation.
 If you are logged in the entire time and respond
to all polling questions, you will be notified via
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CONTACT
 Please email BDOKNOWLEDGE@BDO.COM with
any queries.

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PRESENTERS

Chip Morgan Ingrid Gardner

International Tax Partner International Tax
US Managing Director
UK/US Tax Desk

Jerry Seade Malcolm Joy

International Tax Partner International Tax Partner
US UK

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INTERNATIONAL TAX STRUCTURING
First Venture into Overseas Markets

 Delivery of:  Taxes  Local Country Presence

• Products • Income and Withholding • None
• Services • VAT • Rep Office
• Intangibles • Payroll/Social Security • Permanent Establishment
Contribution
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INTERNATIONAL TAX STRUCTURING
Setting Up More Tangible Presence Overseas

 Operational vs Legal  Following the Cash  Tax Compliance

vs Tax Structure • Coupled with:
cash repatriation
exit strategies

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INTERNATIONAL TAX STRUCTURING
Local Creation/Exploitation of IP

 What do we mean  Where should IP  Tax

by IP? be located? considerations
• Commercial needs • Local incentives
• Substance! • Exit issues
• CFC issues
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INTERNATIONAL TAX STRUCTURING
Wider Consideration of Value Chain Planning as Next Step from IP Migration

Central
Entrepreneur

 Substance and  BEPS – transfer  Changing tax

transparency pricing issues laws

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INTERNATIONAL TAX STRUCTURING
Incentives and Anti-avoidance Provisions

 Patent Box
 Knowledge Box
 R&D tax credits
 Diverted Profits Tax

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INTERNATIONAL TAX STRUCTURING
Planning with the End Game in Mind

 Cost vs Benefit Analysis

 Enhancing/supplementing vs Limiting Value Creation
 Using Advance Agreements

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INTERNATIONAL TAX STRUCTURING
Disclosure of Tax Strategy

Greater transparency as a result of BEPS

Specific UK rules
Public interest

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THANK YOU

CHIP MORGAN INGRID GARDNER

cmorgan@bdo.com | +1 310 557 7517 igardner@bdo.com | +1 212 885 8268

JERRY SEADE MALCOLM JOY

jseade@bdo.com | +1 713 986 3108 malcolm.joy@bdo.co.uk | +44 207 893 3718

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CHIP MORGAN
Partner – International Tax | US

EXPERIENCE SUMMARY
Chip’s career has been centered on international tax for over 30 years. He has been an ITS partner
with two of the Big 4, where he advised clients across a broad range of industries, geographies and
transactions. In addition, he has industry experience as VP Tax for a semiconductor manufacturer
and a software company, where he had practical experience with implementing and defending
international tax structures, and working to keep the tax structures aligned with the underlying
business operations as they evolve over time.
Chip has worked in New York, Brussels, San Jose and Los Angeles and has assisted companies ranging
t: +1 310 557 7517
from startups to very large, mature enterprises. He has deep technical expertise, combined with
e: cmorgan@bdo.com practical hands on experience.
Chip has studied accounting at the University of North Carolina and attended the Columbia Law
School.

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INGRID GARDNER
Managing Director – International Tax | UK/US Tax Desk

EXPERIENCE SUMMARY
Ingrid is Managing Director UK/US Tax desk, based in New York. She has more than 20 years’
international tax experience working with UK and US multinational companies on cross border
structuring, including: financing and IP planning; foreign tax credit management/repatriation
planning; CFC planning; treaty planning; and value chain transformation. Prior to joining BDO, Ingrid
was a principal in the value chain transformation practice of PwC US and prior to that, an
international tax structuring partner in PwC UK.
Ingrid has a Master’s degree in taxation from Fordham University, New York and a Bachelor’s degree in
t: +1 212 885 8268
economic & social studies from the University of Manchester, England. She is a fellow of the Institute
e: igardner@bdo.com of Chartered Accountants in England and Wales and also a member of the Chartered Institute of Tax
in the UK.

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JERRY SEADE
Principal – International Tax | US

EXPERIENCE SUMMARY
Jerry is an international tax principal at BDO in the US. He has over 20 years experience serving mid
to large multinational clients.
He specializes in advising clients on cross-border matters relating to mergers and acquisitions, joint
ventures, offshore structures for intangibles, financing and services companies and outbound and
inbound investments. He also has lead engagement teams on outsourcing of U.S. international tax
reporting services for several multinational clients as well as assisted clients with transfer pricing and
tax accounting (ASC 740) matters.
t: +1 713 986 3108 Jerry has degrees in business and law from the University of Texas at Austin and an LL.M. in Taxation
e: jseade@bdo.com
from the University of Houston. Jerry is fluent in Spanish and is one of the leaders of BDO’s Latin
America desk.

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 MALCOLM JOY
Partner – International Tax | UK

EXPERIENCE SUMMARY
Malcolm is an international tax partner at BDO in the UK . He leads the Value Chain and Transfer
Pricing team and specializes in advising UK and overseas owned businesses on international tax
planning. Malcolm works closely with international tax teams around the world to deliver the most
efficient tax structures to our clients. He is one of BDO’s UK/US liaison partners and is a key member
of the international tax centre of excellence.
Malcolm has more than 20 years’ experience in advising businesses on tax compliance and advisory
matters. His clients range from fast-growing privately owned businesses to major multinationals.
t: +44 20 7893 3718
Malcolm is particularly experienced in cross-border taxation between the UK and the US, intellectual
e: malcolm.joy@bdo.co.uk property ownership and acquisition planning.
Malcolm has a UK degree in business studies and French and has studied at the Sorbonne in Paris. He
is a member of the Institute of Chartered Accountants in England and Wales and also a member of
the Chartered Institute of Tax in the UK.

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THE BDO NETWORK

BDO International statistics as of 9-30-15

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