Jim Alajbegu, partner with Baker Tilly, is the firm leader of the international tax services team. Jim specializes in areas of multinational tax and transfer pricing. Jim has more than 25 years of public and private accounting experience. Prior to joining Baker Tilly, he was a partner and held leadership positions within the international tax practices of a national and an international accounting firm.
- Global tax planning in the areas of GILTI, Subpart F, FDII, BEAT, “check-the-box” planning, foreign tax credit and withholding tax planning, dividend repatriation, holding company planning, debt leveraging and global restructurings to achieve significant reductions in overall effective tax rates
- Assisting with international business startups, expansions, acquisitions and divestitures, including entity selection and international structuring and restructuring recommendations and implementation
- Developing strategies for global leveraging, tax efficient repatriation of foreign earnings, including foreign tax credit planning and treasury cash tax management strategies
- Designing and implementing global holding company and supply chain structures, including super holding companies and regional holding companies for manufacturing, retail, distribution, and technology companies
- Providing M&A due diligence and tax planning for inbound and outbound acquirers (including working with law firms and investment banks)
- Compiling U.S. unilateral and multilateral transfer pricing documentation studies and headquarters’ cost studies
- Implementing global transfer pricing strategies, tariff mitigation strategies, and tax effective supply chain management structures, including intangible and intellectual property migration
- Assisting foreign inbound clients on finance and tax planning, including permanent establishment analyses, treaty-based return positions, 163(j) earnings stripping calculations, and timely and accurate compliance with U.S. federal tax reporting requirements
- Resolving complex international income tax accounting issues, e.g., tax provision calculations, ASC 740 (FIN 48) documentation, including recognition and measurement of uncertain tax positions, assistance with the preparation of technical memorandum and calculation of probability analyses
- Handling audit controversies with the IRS and foreign tax authorities
- Managing global (multi-country) tax compliance outsourcing engagements, including tax provision, tax compliance, VAT compliance, and payroll compliance matters
- American Institute of Certified Public Accountants
- New Jersey Society of Certified Public Accountants International Tax Committee, Chair
- New Jersey Society of Certified Public Accountants Federal Tax Committee, Vice Chair
Location
New York, NY
Education
Bachelor of Science in accounting
Rutgers University