Bruce Jorlando has over 25 years of international tax experience working with Fortune 500 manufacturers. He currently works as the Director of International Tax for Schlumberger Limited, where he focuses on tax efficient supply chain structures and other international tax matters. Previously he held similar director level roles at Cameron International Corporation and Dana Holding Corporation, where he managed all aspects of US and foreign tax planning, compliance, and audits. He has extensive experience with issues such as transfer pricing, foreign tax credits, cash repatriation, and cross-border mergers and acquisitions.
Tax Reform Update for Businesses and Individualsgppcpa
The Trump tax reform is confusing. This presentation will review what businesses and individuals need to know about the changes in the tax law and how those changes impact tax liabilities.
IC-DISCs as a Tax Arbitrage and Wealth Transfer StrategyRoger Royse
Moss Adams International Tax Partner Christine Ballard provides an in-depth look at the structures, benefits, and formalities for Domestic International Sales Corporations
This is a description of our company, services provided, successes and contact information. We are a full service real and personal property tax company with an average of over 12 years experience each.
International tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns discussed include Forms 926, 5471, 5472, 8858, and 8865. The discussion focuses upon proper execution of the Forms and potential penalties for noncompliance.
View the video recording here: https://youtu.be/UyNXjUoFxYA
Learn more about Citrin Cooperman's International Tax Services here: http://bit.ly/2veYkrO
International Tax Reform for US Individuals and Pass-through Entities Fenwick & West
The recent Tax Cuts and Jobs Act has revolutionized the U.S. taxation of international income earned from outbound investment and business operations. While enacted to rationalize the taxation of U.S.-based multinational corporations, these rules have an even more dramatic effect on non-corporate U.S. shareholders of controlled foreign corporations, such as individuals, trusts, S corporations and partnerships. These slides, which were originally presented as part of a Strafford group webinar, provide an overview of GILTI as applied to a non-corporate U.S. shareholder, interaction with Section 962, and review of other international tax reform changes relevant to individual shareholders in foreign businesses.
Un pequeño pero muy lindo Parque Estatal de Minas Gerais en el Brasil. Ofrece bellos paisajes y grandes contrastes entre sus aguas negras y sus arenas blancas como la nieve.
Tax Reform Update for Businesses and Individualsgppcpa
The Trump tax reform is confusing. This presentation will review what businesses and individuals need to know about the changes in the tax law and how those changes impact tax liabilities.
IC-DISCs as a Tax Arbitrage and Wealth Transfer StrategyRoger Royse
Moss Adams International Tax Partner Christine Ballard provides an in-depth look at the structures, benefits, and formalities for Domestic International Sales Corporations
This is a description of our company, services provided, successes and contact information. We are a full service real and personal property tax company with an average of over 12 years experience each.
International tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns discussed include Forms 926, 5471, 5472, 8858, and 8865. The discussion focuses upon proper execution of the Forms and potential penalties for noncompliance.
View the video recording here: https://youtu.be/UyNXjUoFxYA
Learn more about Citrin Cooperman's International Tax Services here: http://bit.ly/2veYkrO
International Tax Reform for US Individuals and Pass-through Entities Fenwick & West
The recent Tax Cuts and Jobs Act has revolutionized the U.S. taxation of international income earned from outbound investment and business operations. While enacted to rationalize the taxation of U.S.-based multinational corporations, these rules have an even more dramatic effect on non-corporate U.S. shareholders of controlled foreign corporations, such as individuals, trusts, S corporations and partnerships. These slides, which were originally presented as part of a Strafford group webinar, provide an overview of GILTI as applied to a non-corporate U.S. shareholder, interaction with Section 962, and review of other international tax reform changes relevant to individual shareholders in foreign businesses.
Un pequeño pero muy lindo Parque Estatal de Minas Gerais en el Brasil. Ofrece bellos paisajes y grandes contrastes entre sus aguas negras y sus arenas blancas como la nieve.
A importância dos professores para a oferta de uma educação de qualidade
para todos é amplamente reconhecida. A formação inicial e continuada, os
planos de carreira, as condições de trabalho e a valorização desses profissionais,
entre outros aspectos, ainda são desafios para as políticas educacionais no
Brasil. No entanto, as condições de trabalho, a carreira e os salários que recebem
nas escolas de educação básica não são atraentes nem recompensadores, e a
sua formação está longe de atender às suas necessidades de atuação. Considerando o papel dos professores na qualidade da educação, é preciso não
apenas garantir a formação adequada desses profissionais, mas também
oferecer-lhes condições de trabalho adequadas e valorizá-los, para atrair e
manter, em sala de aula, esses profissionais.
Tijuco, now known as Diamantina, is a beautiful old city of the State of Minas Gerais, in Brazil. It´s name is related to diammonds and other precious stones that are very abundant in the region.
Chapter 10
International Accounting and Taxation
*
INTERNATIONAL ACCOUNTINGThere is at present no universally accepted definition for international accounting.
International accounting includes all varieties of principles, methods, and standards of all countries.
*
INTERNATIONAL ACCOUNTING (Cont’d)The differences in standards, policies, and techniques reflect varying geographic, social, economic, political, and legal influences of individual countries.
This collection of all accounting principles, methods, and standards is considered the international accounting system.
*
INTERNATIONAL ACCOUNTING (Cont’d)In some countries, such as the United States and Britain, apart from assisting financial decisions by the management, accounting is primarily oriented toward parties external to the business organization who provide capital to it.
Financial reports are very important for the investors and creditors for investment decision making.
*
INTERNATIONAL ACCOUNTING (Cont’d)In some other countries, financial accounting has a different emphasis and performs other roles.
For instance, accounting is mainly used by the government to ensure the collection of the proper amount of income tax in many Latin American countries.
*
GENERAL ACCOUNTING MODELSNo two countries have identical financial reporting and disclosure system.
However, certain countries maintain some similar practices based on close political and economic ties, geographic proximity, and similar legal systems.
*
GENERAL ACCOUNTING MODELS (Cont’d)Almost every former British colony follows British financial accounting practices.
Practices in Canada and Mexico are heavily influenced by U.S. practice due to geographic proximity and close political and economic ties.
*
British-American ModelThis accounting cluster is represented by forty-three countries. It is the most influential model, dominated by the accounting practices used in the United Kingdom and the United States.
*
British-American Model (Cont’d)Apart from being used as an international control tool by managers on a daily basis, the accounting role is relatively oriented toward the decision needs of investors and creditors, since both public ownership and debt financing are greatest in these countries.
*
Continental ModelAccounting in the continental cluster is influenced by the practices found in the continental European countries and Japan. In this model, most countries practice civil law and banks primarily supply capital to businesses.
It is not the primary role of financial accounting to provide timely and sophisticated reports for investors’ decision-making needs.
*
South American ModelNine South American countries are included in this accounting cluster. Spanish is a dominant language in this group except for Brazil, which uses Portuguese.
The most distinctive aspect of accounting practice in this model is the persistent use of adjustment for inflation since all these c ...
TAX 650 Final Project Guidelines and Rubric Overview .docxssuserf9c51d
TAX 650 Final Project Guidelines and Rubric
Overview
The final project for this course is the creation of a memorandum with appendix (7–10 pages).
As an associate working in a privately held enterprise or working with privately held clients, it is imperative to be able to advise clients on the tax implications of
their financial investments. The ability to model the tax consequences of transactions and do cost benefit analysis is crucial.
For your final project, you will model the role of an associate working in a private consulting firm. You will demonstrate your ability to advise clients on whether
they should operate as a sole proprietor, a partnership, an S corporation, or a C corporation. Additionally, using your tax research skills and understanding of
federal income taxation, you will have the opportunity to evaluate tax consequences from sales and distributions for their compliance with the Internal Revenue
Code and Treasury regulations.
The project is divided into four milestones, which will be submitted at various points throughout the course to scaffold learning and ensure quality final
submissions. These milestones will be submitted in Modules Three, Five, Seven, and Eight. The final product will be submitted in Module Nine.
In this assignment, you will demonstrate your mastery of the following course outcomes:
Recommend an appropriate business tax entity based on the analysis of a tax situation for achieving favorable economic impact on the client’s taxable
income
Utilize appropriate tax forms and schedules that compute taxable income on individual tax returns and reflect versatility of thought, resulting in the best
economic solution for the individual taxpayer
Apply accrual and cash basis accounting best practices and moral reasoning in determining when business transactions may be reported for income tax
purposes
Assess the economic impact on taxable income for the business tax entity in relation to Internal Revenue Code and Treasury regulations and the optimum
desired outcomes for the client
Evaluate the tax consequences that result from sales or distributions of property for their compliance with IRS Circular 230, Internal Revenue Code, and
the American Institute for Certified Public Accountants and for advising the client
Prompt
You are currently working at a mid-sized certified public accounting firm. Your client is Bob Jones. Bob, age 60 and single, has recently retired from IBM. He has
$690,000 available in his 401(k) fund and he is thinking of using that money to open a used car business that will be located at 210 Ocean View Drive in
Pensacola, Florida. Bob has estimated that the business might make $300,000 in taxable income.
Bob’s personal wealth including investments in land, stocks, and bonds is about $14,000,000. He reported an interest income of $20,000 and dividend income of
$6,000 last year. The $14,000,000 includes land worth $9,000,000 that B ...
My track record includes collaborating with management teams in setting and evaluating KPIs and profitability goals. Please contact me at 818-808-5107 if you know of a position that can use my experience. Email me at barette@pacbell.net and I will forward a resume to you.
Original air date: Jan. 4, 2018
Recording posted at http://www.mhmcpa.com
The tax reform bill was signed into law on Dec. 22, 2017, bringing sweeping and historic changes to our country’s tax laws. These changes generally are effective in 2018 and impact every taxpayer, from individuals to businesses to trusts and estates, along with not-for-profit organizations as well. We will explore all of the key provisions of the tax reform bill across these sectors, and will offer insight about how the new law differs from prior law.
Tom Barette Resume - Finance ManagementTom Barette
My name is Tom Barette and I am a 10+ corp. financial planning & analysis professional (MBA) in Los Angeles. Seeking opportunities that include modeling, presentations, budgeting and forecasting. My track record includes collaborating with management teams in setting and evaluating KPIs and profitability goals.
Areas of Expertise,
• Financial Planning and Analysis
• M&A Due Diligence Support
• Post Merger Financial Integration
TAX 655 Milestone Two Guidelines and Rubric You will s.docxssuserf9c51d
TAX 655 Milestone Two Guidelines and Rubric
You will submit a draft explaining the tax effects of salaries if cash is withdrawn from a business. You must also explain the tax consequences of paying the
owners based on the taxable entity selected for the business, as well as the tax consequences for each individual’s personal tax returns. This assignment will
address Section I, Parts D and E of the critical elements of the final project.
Specifically, the following critical elements must be addressed:
I. Memorandum
D. Explain the tax effect based on providing $180,000 per year for the client’s salary and $70,000 per year for his daughter’s salary if they withdraw
cash from the business or pay dividends as appropriate.
E. Justify the percentage of ownership the client’s daughter should have in the business based on the type of business entity recommended.
Consider the tax law in reference to the recommendation and how the decision will affect the daughter’s tax return.
Guidelines for Submission: Your paper must be submitted as a 2- to 3-page Microsoft Word document with double spacing, 12-point Times New Roman font,
one-inch margins, and at least three sources cited in APA format.
Instructor Feedback: This activity uses an integrated rubric in Blackboard. Students can view instructor feedback in the Grade Center. For more information,
review these instructions.
Critical Elements Proficient (100%) Needs Improvement (75%) Not Evident (0%) Value
Memo: Tax Effect on Cash
Withdrawals or Dividends
Explains the tax effect based on
providing the client and his daughter
salaries if they withdraw cash from
the company or pay dividends
Explains the tax effect based on
providing the client and his daughter
salaries but details are inaccurate or
cursory
Does not explain the tax effect based
on providing the client and his
daughter salaries
40
Memo: Percentage of
Ownership
Justifies the percentage of ownership
the client’s daughter should have
based on the business recommended
Justifies the percentage of ownership
the client’s daughter should have but
details are irrelevant or cursory
Does not justify the percentage of
ownership the client’s daughter
should have
40
Articulation of Response Submission has no major errors
related to citations, grammar,
spelling, syntax, or organization
Submission has major errors related
to citations, grammar, spelling,
syntax, or organization that
negatively impact readability and
articulation of main ideas
Submission has critical errors related
to citations, grammar, spelling,
syntax, or organization that prevent
understanding of ideas
20
Total 100%
http://snhu-media.snhu.edu/files/production_documentation/formatting/rubric_feedback_instructions_student.pdf
TAX 655 Final Project Guidelines and Rubric
Overview
The final project for this course is the creation of a memorandum with an appendix of supporting IRS forms and schedul ...
TAX 655 Milestone Two Guidelines and Rubric You will s.docx
Resume 9_1_15
1. BRUCE D. JORLANDO
bjorland60@gmail.com
7715 Heathrow Lane Home: 419-824-0331
Spring, Texas 77379 Cell: 419-215-7770
CAREER SUMMARY
Results driven and proactive Director with over twenty-five years of extensive international and federal tax
experience with Fortune 500 manufacturers. Technical skills include strategic global tax planning, M&A,
transfer pricing and supply chain restructuring, local country tax planning, cash repatriation, US and local
tax audits, foreign tax credits, and US tax reporting. People skills include direct supervision of in-house
staff and Big Four loan staff, senior management presentations, partnering with Business Units, IRS and
local tax audit negotiations, and acting as Project Lead for cross-functional reorganizations.
WORK EXPERIENCE
SCHLUMBERGER LIMITED March 2016 - present
On April 1, 2016 Cameron International Corporation was acquired by Schlumberger Limited. My previous
responsibilities under Cameron continue under Schlumberger, with my primary focus being design and
implementation of tax efficient supply chain structure. Additional items with Schlumberger include legal
entity tax restructuring, post-acquisition foreign tax credit planning, cash repatriation, and BEPS transfer
pricing integration and compliance.
CAMERON INTERNATIONAL CORPORATION, Houston, Texas Oct 2010 – March 2016
Tier one oilfield service industry heavy manufacturer with sales of $8bb, operating in over 40 countries. .
Director, International Tax
Interim reporting to Chief Financial Officer. Key responsibilities include managing all aspects of US
international tax planning & compliance, foreign tax credit (FTC) & effective rate planning, global
transfer pricing planning & documentation for Equipment Sales, Intellectual Property (i.e.
Manufacturing Technology, ERP, and Trademark), and Services, tax lead for global supply chain
efficiency project, manage international tax issues of US federal exam & local transfer pricing exams,
global cash repatriation planning, FATCA & FBAR, and supervision of in-house staff, consisting of
two Senior Tax Managers, a Manager, and two Analysts. Cameron’s annual effective tax rate
consistently runs in the low twenty percent. Majority of time spend with Operations, non-tax Corporate
Functions, and outside advisors.
• Manage and enhance high-taxed FTC strategy that annually provides a 3% - 6% ETR reduction.
• Amended 2007 – 2009 Forms 1120 / 1118 to utilize roughly $30M of excess FTC’s and
successfully defended at Federal Exam.
• Cost Sharing Arrangement US/Ireland for Manufacturing Technology
• PCT & Cost Sharing Arrangement US/Ireland for ERP System
• Re-engineered IC Equipment Sales Transfer Pricing – Distributor Lead Model $2BB Sales
• Re-engineered §482-9 IC Service Charges – US, Singapore, Romania, and UK Hubs
• Project/Tax Lead for Centralized Supply Chain Buy/Sell Principal Structure
• Annual cash repatriation strategy - $100M - $500M
DANA HOLDING CORPORATION, Toledo, OH 1997 – 2010
Tier one automotive parts manufacturer with sales of $6bb, operating in 30 countries.
Director, International Tax 2007 – 2010
Reported to VP of Tax. Managing all aspects of US international and local country tax planning, US
compliance, and audits, and supervision of in-house Manager, Senior, and Big Four loan staff.
2. BRUCE D. JORLANDO Page 2
• Worked with Treasury and Legal Departments to develop and implement annual repatriation plan,
including dividends, returns of capital, I / C loans, advance payments, hybrid debt / equity
instruments (Luxembourg CPEC’s). Annual repatriation ranging from $150mm- $400mm.
• Project leader of cross-functional team to covert seven Mexican traditional manufacturers to
Maquiladora status. Migration of $30mm of taxable income to the US.
• Co-Project leader for Strategic Assessment of European Swiss Principle with toll manufacturing
and direct sales, in nine countries with $1.5bb sales. Developed tax and IP migration model,
assisted VAT, local PE, and US substantial contribution review. Annual tax savings $20mm.
• Acted as tax lead for $500mm global divestiture in six countries, provided local country tax and
repatriation planning, purchase price allocation, and negotiation with buyer.
• Established Swiss Global Hedging Center. Provided Section 475 Dealer review, framework for
hedging service agreement and provided local country tax and exchange control review.
• Worked with Corporate Treasury to develop and implement a Pan-European Cash Concentration
Cash Pooling Structure headquartered in Switzerland.
• Performed extensive foreign tax credit (FTC) planning and utilization, including negotiations and
Appeals reruns with the IRS. Annual FTC utilization ranging from $20mm - $200mm.
• US Tax Accounting for APB23 (pre & post Chapter 11), identify and develop FIN48 reserves for
transfer pricing and other issues, and identify deferred tax assets (NOL’s and capital losses) and
the application of valuation allowances (timing and release).
Manager, International Tax 1997 – 2007
• Provided tax counsel for Italian JV with European Partner. Legal and transactional structure
review, IP, and contribution negotiations with partner. Utilized Italian Consortium Tax Relief.
• Member of the Corporate Talent Management Committee that provided comments and
recommendations to senior management to identify, evaluate, and develop in-house staff.
• Provided tax planning and compliance for international portion of $1.1bb divestiture of Global
Aftermarket Unit, including purchase price allocation for fifteen jurisdictions, seller due diligence,
pre - sale restructuring, repatriation, and gain / loss calculations.
• Provided tax counsel for $400mm European acquisition; including legal entity structure, US
purchase of intellectual property and license back, and contract R&D. $1.5mm annual savings.
• Developed global intangibles strategy to centralize U.S. ownership of global R&D platforms for
immediate and or deferred licensing back to foreign operations. Identified and executed 40
license agreements, annually generating $40mm of royalties with $3.5mm tax savings.
• Drafted and implemented annual global transfer pricing process to provide required
documentation and transactional pricing for $900mm product sales, in over 20 countries.
• Created US SG&A Service Agreement and allocation process to charge $40mm annually to
foreign locations – tax documentation, local audit defense and FIN48 determination.
• Negotiated a reduction in multi-year IRS 5701 regarding Puerto Rico 936 transfer pricing, from
$127mm down to $16mm.
• Determined legal structure and type of sale by jurisdiction for $300mm US, European and Asian
divestiture. Assisted in purchase price allocation. Ten jurisdictions.
• Utilized “check the box” to Partnership status to trigger $130mm capital loss in French Holding
Company. Executed similar transaction in Argentina generating an $80mm capital loss.
• Used “check the box” hybrids to create Canadian debt pushdown of $175mm through the transfer
of German Subsidiaries. Double dip, $3mm annual savings.
WHIRLPOOL CORPORATION, Benton Harbor, MI 1996 – 1997
Consumer products manufacturer with sales of $8.5bb, and operations in 30 countries.
Manager, International Tax
All US International tax compliance and planning. 75 controlled foreign corporations, foreign branch
operations, foreign partnerships, foreign sales corporation, and numerous joint ventures and hybrid
entities. Served as Tax representative on cross - functional projects, mergers and acquisitions,
3. BRUCE D. JORLANDO Page 3
transfer pricing, regional tax planning and special projects. Supervised three international tax
accountants.
• Implemented Global R&D Funding and manufacturing intangible license back agreements, that
generated low taxed, foreign source royalty income and $13mm FTC Limitation.
• Provided tax planning for Brazil and Argentina. Coordinated and lead semi-annual tax planning
conference with Brazilian J.V. partner, to reduce local country tax and FTC’s.
DOW CHEMICAL COMPANY, Midland, MI 1990 – 1995
Chemical manufacturer with sales of $20bb, and operations in 70 countries.
Counselor International Tax – Dow Chemical Company 1994 -1995
Manager, International Tax – Marion Merrell Dow, Kansas City, MO 1990 - 1994
SUNDSTRAND CORPORATION, Rockford, IL 1983 – 1990
Aerospace manufacturer with sales of $1.5bb, and operations in 15 countries.
Senior International Tax Analyst
EDUCATION
B.S., Accounting minor in Economics Rockford College, Rockford, IL 1982
PROFESSIONAL
Certified Public Accountant – State of Illinois 1983
Member Houston Chapter Tax Executive Institute Current
Panel Speaker Mayer Brown / Bloomberg BNA Energy Tax Conference Sept 2015
Member Detroit Chapter Tax Executive Institute / Co-Chairman International Tax 1999 – 2010
Member Puerto Rico / USA Foundation (PRUSA) Tax Sub-committee 1993 – 1994
Member and Corporate Panel Speaker FSC / DISC Tax Association 1987 – 1990