Assists clients in structuring business transactions, acquisitions, dispositions, reorganizations, capital formation, financing, joint venture formation and transfer pricing
Works with large multinational corporations and privately held businesses
Miami
@alvarezmarsal
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Ken Brewer is Senior Advisor in Alvarez & Marsal’s Tax practice. He brings over 40 years of professional experience largely comprised of assisting clients in structuring multi-national business transactions, acquisitions, dispositions, reorganizations, capital formation, financing, joint venture formation, and transfer pricing.
His notable areas of expertise include working with large multinational corporations, as well as privately held businesses, both U.S. and foreign-based, on their global tax planning and compliance matters.
In the marketplace, he is sought after and recognized for his ability to understand the tax implications of complex business transactions and arrangements and to identify opportunities to achieve tax savings and avoid so-called “traps for the unwary.”
Mr. Brewer’s extensive background spans a range of international tax matters, including captive insurance and tax treaty issues, taxable presence exposure, tax law aspects of related party transfer pricing and outbound transfers and inversions.
Mr. Brewer earned a BBA in accounting from the University of Massachusetts (Amherst) and a JD from the University of Miami (Coral Gables) School of Law. He is a Certified Public Accountant (CPA) in the Commonwealth of Massachusetts.
NOTE: Alvarez & Marsal employs CPAs but is not a licensed CPA firm.
There is an increased likelihood of double taxation when operating activities under a corporate structure. In an effort to alleviate this, Congress has implemented various deductions that help reduce or eliminate double taxation on corporate earnings when distributed as dividends to other corporations.
Treasury and the IRS recently published a new set of final regulations for taxpayers that conduct business through a foreign branch or disregarded entity whose functional currency is different than that of the taxpayer.
In the past, there has been uncertainty regarding certain IRS interpretations of the dual consolidated loss (DCL) regulations, creating an unintended trap for companies using disregarded entities (DRE's) to conduct foreign operations.
A&M Tax Senior Advisor Kenneth Brewer was recently featured in Tax Notes' article "Proposed DPL Rules May Have IRS Authority Hiccups," highlighting that the DPL rules are complicated and may push companies to restructure operations to avoid tax penalties.
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