Barnes Dennig Transfer Pricing After Tax Reform and COVID-19 120920 - BD | Page 35

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NATIONWIDE SERVICE | 877.525.4462 | KBKG . COM

OTHER COVID / CARES ACT STRATEGIES

CARES ACT Opportunity ?

• Tax NOLs can be carried back five years - 21 % or 35 %(!)

• For multinationals , transfer prices drive where losses incurred

• Changes to transfer pricing may be warranted given COVID

• Numerous Foreign Tax Credit , FDII , GILTI , BEAT , 965 Repatriation complications – but could be significant cashflow