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Briefly summarize the current transfer pricing implications

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Q1) The 2017 Tax Act significantly changed US taxation of international activities ( repatriation/ territorial system, GILTI, FD II, BEAT). Select one new international tax provision, and briefly discuss how that provision has impacted US multinational corporations. Discuss how this provision has impacted US multinational corporations in general or a specific company. Emphasize current developments.

Q2) Your client, a US multinational company is planning to transfer intangible assets,including trade names and trademarks to a low tax offshore subsidiary. This subsidiary would charge royalties to US and foreign subsidiaries for the use of the intangibles.The company also plans to ship products manufactured by its international subsidiary to various worldwide customers.

A) Briefly summarize the current transfer pricing implications and tax reporting considerations your client should consider for both transactions.

B) What other information would you request from the client?

Q3) Amazon initially selected two locations for US headquarters-NYC and Northern Virginia. It withdrew from NYC due to opposition regarding the incentive costs and impact on the environment. New Jersey and other states are reevaluating their incentive grant programs. In general, what is that state and local incentive programs that are effective in maintaining or attracting corporate business?

Reference no: EM132437897

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