Jim Alajbegu is a tax partner in our international tax services group, a practice within Baker Tilly’s specialty tax team. Jim has over 31 years of public and private accounting experience and previously served as the national leader of the international tax services group. Jim provides international tax services to Baker Tilly’s multinational clients in various industries, including technology, manufacturing and distribution, retail and pharmaceutical industries. He has extensive experience with complex international tax matters.
- Global tax planning in the areas of global intangible low-taxed income (GILTI), Subpart F, foreign derived intangible income (FDII), base erosion and anti-abuse tax (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 cash tax and overall effective tax rates
- Assists both inbound and outbound multinational companies with startups, expansions, acquisitions, and divestitures, including entity selection and international structuring and restructuring recommendations and implementation
- Develops global tax strategies for global leveraging, tax efficient repatriation of foreign earnings, including foreign tax credit planning, treasury cash tax management strategies and foreign tax minimization
- Provides M&A due diligence and tax planning for cross-border reorganizations, acquisitions, and dispositions, including tax-efficient cash redeployment, financing, and post-acquisition integration of acquired operations
- Assists inbound clients on finance and tax planning, including permanent establishment analyses, treaty-based return positions, earnings stripping calculations, and timely and accurate compliance with U.S. federal tax reporting requirements
- Resolves 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
- Handles audit controversies with the IRS and foreign tax authorities
- Manages global (multi-country) tax compliance outsourcing engagements, including tax provision, tax compliance, value-added tax (VAT) compliance, and payroll compliance matters
- American Institute of Certified Public Accountants (AICPA)
- New Jersey Society of Certified Public Accountants International Tax Committee, Chair
- New Jersey Society of Certified Public Accountants Federal Tax Committee, Vice Chai
- “Foreign taxes on PTEP can provide additional foreign tax credits”, co-author, The Tax Adviser, October 2021
- “Foreign income taxes deemed paid and the PTEP rules”, co-author, The Tax Adviser, October 2020
- “What is a permanent establishment? And the risks of doing business globally under the TCJA and BEPS”, Baker Tilly, January 2019
- “Demystifying the new international E&P rules”, The Tax Adviser, October 2019
- “Transfer pricing roundtable”, Financier Worldwide Magazine, February 2013
- “Supply chain management”, Financier Worldwide, February 2012
- “Transfer pricing in today’s global environment”, NJ CPA Magazine, November 2009
Location
New York, NY
Education
Bachelor of Science in accounting
Rutgers University