CITD Seminar - International Business Relations

The seminar will focus on global trade issues that affect how US companies do business with their international customers, including the regulatory frameworks of Free Trade Agreements such as NAFTA, using international tax treaties with other countries to your best advantage, and also current trends in outsourcing.

This seminar is one of a nine-part seminar series on international business and is supported by the US Department of Commerce and the Small Business Association.

Date: Tuesday, January 18, 2005
Location: USDoC, 250 Montgomery Street, 14th floor, San Francisco CA 94104
Time 8:45 am - 1:00 pm

08:45 - 09:15 Registration and Networking
09:15 - 09:25 Introductions
09:25 - 10:40 Jack Kilmartin, Terra Nova Trade Services – an overview of NAFTA and how Free Trade Agreements affect US international trade.
10:40 - 11:10 break
11:10 - 11:30 Keith Rayner, Kemarra Inc. - Current trends in outsourcing - what this means to the US economy in both the short and long term, and how can the US best adapt to take advantage of outsourcing.
11:30 - 12:10 Marcus Sharei, Hood & Strong LLP, International tax structuring for US companies
12:10 - 12:30 Panel discussions and questions
12:30 - 13:00 Networking

The panel moderator will be Keith Rayner of Kemarra, Inc.

Speaker Bios

Jack Kilmartin
Jack Kilmartin founded Terra Nova Trade Services, a Customs Brokerage firm, in 2003. Tailored to the needs of new and small businesses, it has helped many new entries into the field of import and export. With many years experience in logistics, supply chain management and Customs matters, he and his staff are a valuable resource to the trade community. Their specialties include Customs rules and regulations, trade programs, duty drawback, and post-entry representation.
Mr. Kilmartin is a credentialed teacher and has been a licensed Customs Broker since 1990. He began his career in international trade as a Peace Corps Volunteer in Costa Rica, where he served from 1983 to 1986. He graduated with a B.A. degree in Economics from the University of California, Davis, in 1982.

Marcus Sharei
Marcus is currently Director of the International Tax & Transfer Pricing Group at Hood & Strong LLP CPAs.

He was formerly Director of Tax and Treasurer for Flextronics International, Ltd., a $2 billion publicly-traded, global high-tech electronics manufacturer with 50 foreign subsidiaries operating in 20 countries in Europe, Asia and China, Brazil, Mexico, and the United States. While there, Marcus improved cash flow by permanently lowering the firm’s overall corporate income tax rate to 12%, through a combination of foreign restructuring and transfer pricing initiatives.

Marcus has also worked in tax management and supervisory positions with Coopers & Lybrand, Warner Bros., Inc., and Arthur Andersen. His international clients have included Samsung, Levi Strauss, McAfee, Clarify, Diamond Multimedia, Olivetti, Toyota Motor, and NEC, as well as Warner Bros. Records and Warner Bros. (motion picture) Distributing, Inc.

Marcus’ specialty is the creation of methods and foreign tax structures to lower a corporation’s overall income taxes and cash expense. Examples include:

• Create tax deductible licensing royalties, by moving ownership of operating intangibles and other intellectual property to low tax nations
• Identify foreign tax subsidies for new or continuing operations such as ETI and I/C DISCs, and 3-10 year “Pioneer” income tax exemptions
• Minimize foreign withholding taxes, by determining the tax efficient transfer route of inter-company funds, dividends, loans, and interest
• Create off-shore factoring of U.S. receivables
• Recommend the ideal debt-equity capitalization in new countries
• Determine the appropriate form of operating entity in new countries (branch, corporation, partnership, or joint venture)
• Assist with minimizing import/export taxes, customs, and duties
• Review draft contracts to reduce foreign tax implications:
  • Maximize Section 863(b) offshore profit allocations between the sales and manufacturing functions
  • Identify key terms to include for beneficial tax treatment