International Overview Training - Topic IV - Global Tax Org Chart Post Tax Cuts and Jobs Act of 2017

Sep 12, 2026

International Overview Training: Topic IV explains how Global Tax Organizational Charts (GTOCs) help issue teams understand a company’s tax planning strategies after the 2017 tax reforms. The material outlines IRS front matter items, core ethical and taxpayer-rights concepts, and how GTOCs use standard symbols to represent entity types. It also covers how to interpret taxpayer objectives, analyze transactional flow for exam risk, and apply global planning approaches such as lowering ETR, managing tax risks, and aligning planning with business strategy.

LanguageEnglish

CategoryPresentations

FormatPDF

Pages63

Reading Time22 min

AccessFree to download

Global Tax Org Chart – Post Tax Cuts and Jobs Act of 2017

IRS front matter items

Overview of GTOCs and their use

Learning objectives

Taxpayer’s objectives in global tax planning

How taxpayers achieve global tax planning objectives

International Overview Training: Post-2017 Tax Reform Topic IV Global Tax Org Chart – Post Tax Cuts and Jobs Act of 2017 IRS Front Matter Items 􀂃 The IRS Mission Statement 􀂃 14 General Principles of Ethical Conduct for Federal Employees 􀂃 Your Rights as a Taxpayer 2 Overview 􀂃 Global Tax Organizational Charts (GTOCs) provide key information to issue teams about a company’stax planning strategies • Understanding a taxpayer’s tax planning objectives is key in issue identification 􀂃 GTOCs use standard symbols in industry to represent different types of entities for US tax filing purposes • Review of taxpayer’s GTOC structure provides valuable exam risk information (i.e. , what US compliance is required and what types of global tax structures are in place) 3 Overview (Cont’d) 􀂃 Transactional flow analysis using a company’s step plan org charts may assist in exam risk identification • Details matter – transactional analysis of step plans provides key insight into taxpayer’s filing position regarding an acquisition, disposition or restructuring transaction 4 Learning Objectives At the end of this lesson you will be able to: A. Identify taxpayer's objectives in global tax planning B. Interpret a taxpayer’s GTOC C. Use GTOCs to identify taxpayer’s planning objectives 5 A. Taxpayer's Objectives in Global Tax Planning Basics of Strategic Global Tax Planning 􀂃 In conducting and structuring business operations, a Multinational Enterprise (MNE) may consider its strategic global tax plan. 􀂃 A company’s strategic global tax plan could strive to: • Increase Earnings Per Share (EPS) • Minimize Effective Tax Rate (ETR) • Manage cash and expenses • Manage tax risks 7 Basics of Strategic Global Tax Planning (Cont’d) 􀂃 Sustained, predictable improvements in EPS • Increase share price and total market capitalization • Possibly boost executive compensation when tied to EPS 􀂃 Reduce Tax Expense • Tax expense directly reduces net income, which unfavorably lowers EPS 􀂃 Control Costs • Companies try to manage costs efficiently (including taxes) to produce shareholder value • Tax costs can be managed efficiently through permissible planning 8 How Do Taxpayers Achieve Global Tax Planning Objectives? 􀂃 Reduce ETR, for example, by: • Generating income in offshore low tax jurisdictions • Reducing net income by borrowing and other strategies − Minimizing exposure to IRC 163(j), 267A, Global Intangible Low-Taxed Income (GILTI) and Base Erosion Anti-Abuse Tax (BEAT) • Maximizing income taxed as Foreign Derived Intangible Income (FDII) • Maximizing income subject to the participation exemption • Minimizing US and foreign income taxes • Utilizing past and current foreign losses for tax benefit • Because certain foreign earnings when repatriated no longer bring FTCs, US MNEs may affirmatively plan into Subpart-F for high tax CFCs, which would bring back FTCs. 9 How Do Taxpayers Achieve Global Tax Planning Objectives? (Cont’d) 􀂃 Manage tax risks within global tax strategy • Strategic planning that is integrated into the business strategy • Minimization of tax and treasury risks • Shift tax risk to lower tax jurisdictions • Tax risk may come from a variety of sources including business model, transaction flows, tax law changes, tax planning, execution and maintenance of transactions, people, etc. • Shifting intangible property and related income to lower tax jurisdictions, while avoiding 367(d) exposure 10

FAQs

What strategies help reduce effective tax rate (ETR)?

Strategies include generating income in offshore low-tax jurisdictions, reducing net income through borrowing and related approaches, maximizing FDII, maximizing participation-exemption income, minimizing US and foreign income taxes, and using past and current foreign losses for tax benefit.

Sep 12, 2026

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