Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, a Director and one of the faces of our International Tax team. Frank, welcome back to the playbook.

Frank: It’s great to be back.

Jen: In our last segment, we were talking about mistakes that multi-foreign multi-national companies can make when they’re doing some debt financing. Can you elaborate a little bit more on that?


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, a director and one of the faces of our International Tax team. Frank, welcome back to The Playbook.

Frank: Thanks for having me again. It’s a pleasure.

Jen: We’ve covered all sorts of international topics, but one thing we haven’t touched on is tax reform for tax planning strategies for multinational companies coming inbound.

Frank: That’s right. The rules have changed and tax reform, you know, the biggest development is the change in our tax rate for corporations since most inbound companies do business as a corporation and we’ve gone to 21% tax rate. There are revised rules for interest expense deductions and new rules regarding our net operating loss carryforwards.

Jen: Is there any kind of things people should be aware of for a financing strategy for when they’re coming inbound?


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our International Tax Directors. Frank, welcome back to The Playbook.

Frank: Thanks. It’s exciting to be back.

Jen: I know there’s been some new changes to the Foreign-Derived Intangible Income, or FDII, as we’ve been calling it, that released in early March. What do we need to know about the new changes?

Frank: That’s right. Even though it’s interesting about this new tax law is that, even though it was passed a little over a year ago, guidance is still trickling in. Even though a law has been on the books, usually you do planning on a go-forward basis. There is some planning to go back and see about opportunities you may not have had.


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our International Tax Directors. Frank, welcome back to The Playbook.

Frank: Thanks, Jen. Thanks for having me back.

Jen: We’ve talked about GILTI and FDII in previous episodes, and now I know there’s some more foreign impacts with the new tax reform. Is there anything else you can share with us about that?

Frank: Yes, in response to the Tax Reform Act, Treasury has had to come up with new rules for four tax credits. For example, previously, we had two types of foreign tax credit baskets.
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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our International Tax Directors. Frank, welcome back to The Playbook.

Frank: Thanks, Jen. It’s great to be back.

Jen: We’ve been talking about IC-DISC, and last time we talked about tax reform. What’s changed strategy wise since before tax reform and now after tax reform?

Frank: I think with IC-DISC it’s kind of a Back to the Future type of thing, because when the IC-DISC came out, it was really meant to be a deferral tactic and to really get tax advantages, because you’re deferring the recognition of the IC-DISC income, or really, the export income.
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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our International Tax Directors. Frank, welcome back to The Playbook.

Frank: Thanks, Jen. It’s great to be back.

Jen: I know there’s an incentive for exporters: IC-DISC. How has that changed with tax reform?

Frank: That’s a good question. It’s been around for quite a while, as you know, the IC-DISC is nothing new. What propelled its novelty is the tax reform of 2003 where dividend rates were now coupled with capital gains rates. There’s been legislation on and off of repealing it or modifying it or limiting it in some kind of way, but oddly enough, tax reform did not change anything with regard to IC-DISC, so it’s still a viable option for exporters.

Jen: So Frank, how can the IC-DISC be helpful for our viewers?


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our International Tax Directors. Frank, welcome back to The Playbook.

Frank: Thank you. It’s good to be back with you.

Jen: In a previous segment we went over transfer pricing, and we touched on it just a little bit, but I know we want to do a deeper dive. So, with tax reform and transfer pricing, what else do folks need to know?


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our international tax directors. Frank, welcome back to the Playbook.

Frank: Well, thank you, Jen. It’s great to be back.

Jen: I’ve heard some headlines about transfer pricing. Can you give our viewers

Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our international tax directors. Frank, welcome back to the Playbook.

Frank: Well, thanks for having me back.

Jen: So, we’ve been covering international tax reform. What else do people need to know? What