Jim Alajbegu, Partner with Baker Tilly Virchow Krause, LLP, is a member of the international tax practice and the specialty tax services team. He specializes in areas of multinational tax and transfer pricing. Jim has nearly 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 “check the box” planning, Subpart F mitigation, foreign tax credit planning, dividend repatriation, holding company planning, debt leveraging, and global restructurings to achieve significant reductions in overall effective tax rates.
- Assisting with international business start-ups, expansions, acquisitions, and divestitures, including entity selection and international structuring and restructuring recommendations and implementation.
- Developing strategies for tax efficient repatriation of foreign earnings, including foreign tax credit planning and treasury cash tax management strategies.
- Designing and implementing global holding company 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 in-bound and out-bound acquirers (including working with law firms and investment banks).
- Compiling US unilateral and multilateral transfer pricing documentation studies and headquarters’ cost studies.
- Implementing global transfer pricing strategies and tax effective supply chain management (TESCM) structures, including intangibles and intellectual property migration.
- Assisting foreign in-bound clients on finance and tax planning, including earnings stripping calculations, permanent establishment analyses, treaty-based return positions, and timely and accurate compliance with US 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 international tax compliance outsourcing engagements
- 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,
Bachelor of Science in Accounting, Summa Cum Laude