Deducting Interest Paid by Multinational Corporations: Section 163(j), 263(a)(3), Thin Capitalization Rules, OECD

Ms. Belyavskaya has 15 years of experience working with multinational businesses and high-net-worth individuals. She provides tax compliance and advisory services on cross-border transactions, corporate international restructuring, U.S. entity formation and dissolution issues, as well as global mobility matters and expatriate tax assistance. Ms. Belyavskaya has worked with numerous clients and PKF colleagues around the world on transfer pricing issues and U.S. nexus tax regulations. She has prepared numerous memoranda regarding U.S. tax implications for foreign clients, and she is a contributor to the Firm’s Thought Leadership series. Currently, Ms. Belyavskaya is spearheading the Firm’s efforts to grow its client base in the Commonwealth of Independent States (CIS) in Eastern European and Asian countries. 

Mr. Ford has more than 20 years of experience advising private equity sponsors, middle-market companies, multinational organizations and business owners on complex transactions. He specializes in buy-side and sell-side tax due diligence, transaction structuring, tax modeling and identifying and mitigating federal, state and international tax risks. Throughout his career, Mr. Ford has advised on transactions ranging from less than $1 million to more than $2 billion. He has developed particular expertise in Section 1202 planning, F reorganizations, tax attribute optimization, renewable energy tax credits and post-closing integration. Mr. Ford is also a recognized technical educator and thought leader. He has authored articles on complex tax matters, led national training programs and taught a master’s-level course on mergers and acquisitions at Yeshiva University.

Mr. Parmegiani has over 30 years of experience in public accounting. He has considerable expertise in a broad range of tax specialty areas, including the hospitality and real estate industries, both domestic and international business investments, sales and use tax, C Corporations, S Corporations, Partnerships, LLCs and REITs, and state and local tax issues. Mr. Parmegiani has worked extensively with high net worth individuals, including United States taxpayers living abroad and foreign nationals living in the United States and advises foreign groups in establishing domestic business operations. He has years of experience in cross border tax structuring, transfer pricing issues and tax examination representation. Mr. Parmegiani heads up the Firm’s international tax practice, is a member of the Firm’s Tax Leadership Committee and is Chairman of PKF International’s Internationally Mobile Individual Tax Committee.