Legal Entity Rationalization in a Post-TCJA World

Moderator :

Cathleen Stevens, Brunswick Corporation


  • Elizabeth A. Andrews, DLA Piper
  • Rafic H. Barrage, Baker & McKenzie LLP
  • Kevin M. Jacobs, Alvarez & Marsal Taxand, LLC

Session Description:

The world economy is facing ever-changing supply chain limitations due to tax reform and the COVID-19 pandemic. This panel will discuss the key legal and tax considerations for implementing legal entity rationalization in a post-TCJA world and pandemic-disrupted economy. Various discussion points will include TCJA guidance (e.g., on GILTI, FDII, BEAT, FTC, section 163(j)), the impact of the November 2020 election, and other world events.

Learning Objectives:

After this session, participants will be able to: (1) articulate the benefits of engaging in legal entity rationalization (LER); (2) understand the LER process at a high level; and (3) understand how the TCJA and its numerous regulations impact the analysis and provide opportunities to unlock hidden value.

Location: Date: March 24, 2021 Time: 3:45 pm - 5:00 pm