Varian Medical Systems and Forte International Tax Tackle GILTI/FDII and Foreign Tax Credits.

• Author: Gasbarra, Mark
• Position: Global intangible low taxed income, foreign derived intangible income

This is the second installment of our Tax Technology Corner. As a corporate tax professional, you know how important technology is and how it's evolving at warp speed. With new regulatory and compliance initiatives in the federal, state, local, and international areas, landmark tax reform legislation, and globalization of tax monitoring and enforcement, keeping up with tax technology is not a luxury--it's a necessity. Each installment of this column will pair a taxpayer with a service provider. Together, in Q&A format, they'll tell a story about how they have worked together to solve a specific tax problem, implement a better solution, cut costs, or improve productivity. In this installment, Mark Gasbarra, national managing director for Forte International Tax LLC, and Brian Pollard, vice president of tax at Varian Medical Systems Inc., discuss an intriguing tax issue they successfully handled together. Michael Levin-Epstein, senior editor of Tax Executive, moderated the discussion.

Michael Levin-Epstein: Brian, please tell us about your company.

Brian Pollard: Varian is the world's leading manufacturer of medical devices and software for treating cancer and other medical conditions with radiotherapy, stereotactic radiosurgery, stereotactic body radiotherapy, brachytherapy, and proton therapy. Our vision is a world without fear of cancer. Our mission is to combine the ingenuity of people with the power of data and technology to achieve new victories against cancer. To meet this challenge, we offer comprehensive solutions for fighting cancer.

Levin-Epstein: Mark, please tell us about your company.

Mark Gasbarra: Forte International Tax LLC is an international tax specialty firm. We leverage our proprietary software platform, VantagePoint [TM], to meet the complex planning and compliance needs of multinational enterprises. Our team has continually served the international tax software and services market since 1981 and has programmed software for every major international tax change since then, including the Tax Reform Act of 1986. Before founding Forte in 2004, our principals led international tax practices and developed international tax software for Price Waterhouse (PwC) and EY. VantagePoint represents a high point in our development efforts, including GILTI, FDII, and other TCJA international tax provisions.

The Tax Issue

Levin-Epstein: Brian, describe the issue that you were looking for help for from Mark's group.

Pollard: I think it's...