Russ: This is the PKF Texas Entrepreneur’s Playbook. I’m Russ Capper, this week’s guest host, and I’m here once again with Frank Landreneau, a Director and one of the faces of the International Tax team here at PKF. Frank, welcome back to The Playbook.

Frank: Thank you.

Russ: Our last time together, we got into the Tax Cut and Jobs Act, and of particular interest to me was how the interpretation of how you handle certain things from that Act has sort of evolved and matured and maybe even changed over time now that we’re in it two years. There was one particular—I had asked you to give me an example of how that rolls out, and you said, “Yeah, there’s this one part of running an international business, where there’s, like, three options that have evolved, really.” Mainly, from international tax people like you. One was literally to create a corporation and, correct me if I’m going down this path wrong, but one was to create a corporation.

Frank: That’s correct.

Russ: The second one was to actually elect a holding company that would play like it was the company.

Frank: That’s right.

Russ: And the third, mostly I guess for SMEs, was to actually create something that you’re just treated like a foreign company. Was I even close on those three?

Frank: Very close, actually. In tax law there is a lot of elections that create a tax treatment that may not be in line with legal structuring and so forth.

Russ: Yeah, you want to avoid that legal stuff, don’t you?


Continue Reading Three Structuring Options for International Business

Russ: This is the PKF Texas Entrepreneur’s Playbook. I’m Russ Capper, this week’s guest host, and I’m here with Frank Landreneau, Director and one of the faces of the International Tax team. Frank, welcome back to the Playbook.

Frank: Thanks, Russ. Thanks for having me; always a pleasure.

Russ: You bet. Next time you’re on I am going to count to see how many times have you been on, because I’m sure it’s more than anybody else.

Frank: Okay, great.

Russ: But our topic today is primarily going to be the Tax Cut Jobs Act that I think was passed in 2017, started in 2018, and it’s mind boggling to me, because we’re still sorting that thing out. Is that right?

Frank: That’s exactly right. And it’s been a little bit over two years, but we’re still getting guidance even now and even there’s pending guidance that we’re anticipating on getting even this year as we speak.

Russ: How does a business person make decisions based upon this thing playing out over such a long period of time?


Continue Reading Restructuring Strategies for Small- to Medium-Sized Businesses

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?


Continue Reading Debt Financing – What You Need to Know

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.


Continue Reading Following Up on FDII Changes from March 2019

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: So, last time we talked about international tax baskets with the new tax reform. What are some issues that business owners are finding with that?


Continue Reading Opportunities and Traps in the International Business Space

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.
Continue Reading Foreign Tax Baskets – What to Know

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.
Continue Reading Your IC-DISC Strategy: Does it Need to Change?

In our continuing effort to help co-create solutions for business’ future, we offer the following ideas, insights and perspectives in the latest edition of the Leading Edge Digital Magazine. These thought leadership pieces are ready to be accessed any time, anywhere at LeadingEdgeMag.com/PKFTexas.

If you have topics you would like us to cover, contact us. As always, we enjoy receiving comments and feedback from our clients and the friends of our firm.


Continue Reading Winter 2019 Leading Edge Magazine is Now Live

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?


Continue Reading How Your Business Can Benefit from IC-DISC

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?


Continue Reading A Closer Look at Transfer Pricing and the International Space