Cathleen Stevens, Brunswick Corporation
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.
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.