water’s-edge – inbound structure · 2016-02-04 · bdo knowledge webinar series...

BDO KNOWLEDGE Webinar Series ‒ Water’s-Edge – Inbound Structure

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BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. @BDO_USA_Tax

Water’s-Edge – Inbound Structure

February 1, 2016


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CPE AND SUPPORT

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WITH YOU TODAY

Chris BerknessSenior Tax DirectorBDO USA, LLP

One Bush StreetSuite 1800San Francisco, CA 94104Direct: (562) 481-1032 Email: [email protected]


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LEARNING OBJECTIVES

• Describe effectively connected income partial inclusion rules• Recall the 20% U.S. apportionment factor full inclusion rule• Identify the requirements to properly elect water's-edge• Construct forms needed to properly elect water's-edge


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AGENDA

• Tools needed to prepare water’s-edge schedules• Effectively connected income – partial inclusion rules• 20% US apportionment factor full inclusion rule


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WATER’S-EDGE ELECTION

• By electing water’s-edge, a taxpayer will have to apply a unique blend of multistate and international taxation concepts.

• The general rule excludes foreign corporations from the combined report. However, there are several exceptions to the general rule.

• The more common exceptions are the Subpart F inclusion ratio, effectively connected income and the 20% rule.

• The following presentation will cover the ECI and 20% inclusion rule.

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TOOLS NEEDED TO PROPERLY PREPARE WATER’S-EDGE SCHEDULES

• Organization Chart:• Ownership percentage • Proper entity classification (corporation, DRE or partnership)

• Federal forms:• 5472 (California conforms to federal penalties)• 1120F – US Income Tax return of a Foreign Corporation• 926 – Transfer of property to foreign entities (California conforms to federal penalties)• 1120 – Federal consolidated return

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EFFECTIVELY CONNECTED INCOME – PARTIAL INCLUSION

• Effectively Connected Income (ECI)• The general rule is that foreign corporations are excluded from the water’s-edge combined

report, however, if the foreign entity has ECI, then it will be included in the combined report to the extent of the ECI.

• There must be a unitary relationship in order to partially include a foreign corporation in the combined report based on ECI.

• If the foreign corporation is included in the combined report to the extent of ECI, then the effectively connected sales (if single sales factor) will be included in the apportionment factor.

• The ECI must be considered business income within the meaning of section 25120.• Deductions are allowed against gross ECI under Treas. Reg. 1.861-8 and 1.882-5.• Any applicable state adjustments should be made to the ECI.• California does not apply the provisions of US tax treaties to the extent they limit ECI.

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EFFECTIVELY CONNECTED INCOME – FILE 1120F

• Treas. Reg. 1.6012-2(g)(1) requires a foreign corporation that is engaged in a trade or business in the U.S. to file an 1120F.• The 1120F is required even if the foreign corporation resides in treaty country.• The 1120F is required even if the foreign corporation does not have any ECI or US sourced

income.• If an 1120F is not filed, then deductions could be denied.

• The FTB will request copies of all 1120F’s filed with the IRS to determine if the foreign corporation should be partially included.

• Since California does not apply the provisions of US tax treaties to the extent they limit ECI, a foreign corporation could still be partially included in the combined report even though ECI is not taxable for federal purposes.

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EFFECTIVELY CONNECTED INCOME – ACTIVE TRADE OR BUSINESS

• In order for the foreign corporation to have ECI, it must have an active trade or business in the United States.

• There is no clear definition of an active trade or business in the statute or regulations, instead the definition has been left up to the courts to decide.

• In general, an active trade or business will exist if the foreign corporation (or its agent) is engaged in activities for the production of income that are considered regular, continuous and considerable.

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EFFECTIVELY CONNECTED INCOME – ACTIVE TRADE OR BUSINESS

• FTB will not only request all 1120Fs, but they may also ask for financial statements that may indicate property or employees located in the US.

• FTB will research the internet to determine if the foreign corporation has any connection with the US (office, warehouse, employees, contracts, customers etc...)

• FTB will ask if the foreign corporation has any contracts with business entities or persons located in the US in order to determine if an agency relationship exists.

• FTB will ask if the foreign corporation has any intangible assets protected in the US.

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EFFECTIVELY CONNECTED INCOME – FORCE OF ATTRACTION

• Once an active trade or business has been established in the US, then all US sourced income will be considered ECI except FDAP. This is sometimes referred to as the force of attraction rule.

• For federal purposes, the force of attraction rule may not apply if the foreign corporation resides in a treaty country. Since California does not follow US treaties for water’s-edge purposes, the force of attraction rule will apply in determining ECI.

• In general only US sourced income can be considered effectively connected however, there are exceptions that apply to foreign sourced income. The exceptions only apply if an office or fixed place of business exists in the US.

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EFFECTIVELY CONNECTED INCOME – AGENCY RELATIONSHIP

• The activities of an agent can establish a US trade or business.• The agent doesn’t have to be considered dependent in order to establish an

active trade or business.• Although an independent agent can establish an active trade or business for a

foreign corporation, it cannot establish an office or other fixed place of business for the foreign corporation. Only a dependent agent can establish an office or other fixed place of business. The dependent agent must habitually exercise (in the US) an authority to conclude contracts that are binding on the foreign corporation.

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EFFECTIVELY CONNECTED INCOME – PERMANENT ESTABLISHMENT

• The threshold for establishing a US trade or business is much lower than the threshold for creating PE.

• PE generally requires a fixed place of business through which a foreign corporation engages in a trade or business.

• If a foreign corporation resides in a treaty country, it will only be taxed on the trade or business income that is attributable to a PE.

• If a foreign corporation resides in a treaty country and it does not have a fixed place of business in the US, then typically the determination of an active trade or business is not necessary for federal purposes.

• Although this may not be an issue for federal purposes, it can be for California purposes. California does not apply the provisions of US tax treaties to the extent they limit ECI.

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EFFECTIVELY CONNECTED INCOME – PERMANENT ESTABLISHMENT

• Since California does not apply the provisions of US tax treaties to the extent they limit ECI, would FTB want to determine if an office or fixed place of business exists in the US?• Yes, if it is determined that an office or fixed place of business exists in the US and that office is

a material factor in the production of income, then certain types of foreign sourced income can be included as ECI.

• In addition, the determination of an office or fixed place of business could directly affect the 20% rule which will be discussed later.

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EFFECTIVELY CONNECTED INCOME – ACTIVE TRADE OR BUSINESS (E-COMMERCE – CLOUD COMPUTING)

• The determination of an active trade or business becomes much more difficult when the income earned is from the internet or cloud based computing transactions.

• There are no cases that directly apply to companies that earn revenue from cloud based computing or internet services, Piedras Negras Broadcasting Co. v. Commissioner, 43 B.T.A. 297 (1941) is the case that is commonly referred to with regard to these types of transactions.

• Based on Piedras, if a foreign corporation generates income from US customers without having any property or labor located in the US, then it would appear the foreign corporation would not be considered to have an active trade or business in the US. (Servers?)

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• However, if a foreign corporation owns intangible assets (trade name, trade mark, copyright or patent) that are utilized in the US and it receives income from US customers, then it may be considered to have an active US trade or business.

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• The IRS has not provided any guidance with regard to e-commerce or cloud based computing transactions. The OECD has provided some guidance with regard to e-commerce. • Websites do not constitute a permanent establishment.• Website hosting facilities should not produce a permanent establishment for the entity carrying

on the business through the website.• ISP’s should not represent a dependent agency position and therefore, give rise to a permanent

establishment. However, they can constitute independent agents. Could an ISP establish an active trade or business for the foreign corporation?

• Servers located in a jurisdiction for a long period may be considered fixed and constitute a permanent establishment.

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EFFECTIVELY CONNECTED INCOME – U.S. SOURCED INCOME

• In order to determine if the income is US sourced, the federal sourcing rules under IRC §861-863 and §865 are applied.

• With regard to transactions involving computer programs, Treas. Reg. §1.861-18 addresses the classification and sourcing rules.

• It is important to realize that these federal sourcing rules are much different than the rules under R&TC §25135 and §25136(b) which are used for apportionment factor purposes.

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EFFECTIVELY CONNECTED INCOME – SOURCING RULES (E-COMMERCE – CLOUD COMPUTING)

• As discussed earlier, there isn’t much guidance for determining if a foreign corporation, that generates income from e-commerce or cloud based computing, has an active trade or business or PE in the US.

• In addition, there isn’t a lot of guidance for determining the source of this income. (The OECD has suggested that the country where the customer is located should be where the income is sourced.)

• The first issue that needs to be addressed is how to categorize the income. Is it a sale of tangible personal property, leasing agreement, licensing agreement or services?

• Once the income is properly categorized, then additional issues need to be addressed. Is the location of the servers going to dictate where the services are provided or where the property is used? Is the location of the customer an important factor?

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EFFECTIVELY CONNECTED INCOME – FDAP

• Fixed or determinable, annual or periodic income (FDAP) typically consists of interest, dividends, rents, royalties, annuities and wages. There are other items listed in IRC §871.

• For federal purposes, FDAP is subject to withholding tax at a rate of 30% (unless a treaty applies). No deductions are allowed against FDAP.

• If FDAP is considered effectively connected income, then deductions will be allowed and the 30% withholding tax will not apply.

• The asset-use test and the business-activities test are applied in order to determine if FDAP is considered effectively connected. If either test is met, then FDAP will be considered ECI.

• Under the asset-use test, the income earned from assets used in a US trade or business will constitute ECI.

• If the activities of a US trade or business are material in the generation of FDAP income, then the income will be considered effectively connected under the business activities-test.

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EFFECTIVELY CONNECTED INCOME – FDAP

• For California purposes, FDAP income is no longer included in the water’s-edge combined unless it is considered effectively connected income.

• Therefore, the FTB may want to determine if the asset-use test or business-activities test is met since FDAP is only included in the combined report if it is considered effectively connected income.

• There may be situations where the IRS does not need to determine if FDAP is considered effectively connected but it could be an issue that the FTB will want to pursue.

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EFFECTIVELY CONNECTED INCOME – EXAMPLE 1

• Foreign Corporation develops a software program in a foreign country A, where it is headquartered. Foreign Corporation obtains a copyright in the Unites States for the program. In addition, Foreign Corporation owns a valuable trade name and trademark in the United States that it uses on all of the products it sells. Foreign Corporation plans to sell the software in the United States.

• Foreign Corporation enters into a licensing agreement with California Corporation where California Corporation will reproduce the software on compact disk and they will use the valuable trademark and trade name on all of the compact disks sold in the United States. California Corporation will pay Foreign Corporation a royalty for each disk sold.

• The licensing agreement is for a term of 3 years and after that period all rights revert back to Foreign Corporation. Not all substantial rights in the copyright have been transferred to California Corporation.

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• The first step is to determine if Foreign Corporation has an active trade or business in the US.

• In general, an active trade or business will exist if the foreign corporation (or its agent) is engaged in activities for the production of income that are considered regular, continuous and considerable.

• Foreign Corporation owns valuable intangible assets in the US and sells its software programs to customers in the US. Are these activities regular, continuous and considerable? Would the relationship with California Corporation be considered an agency relationship?

• Although Foreign Corporation does not have any employees or tangible assets located in the US, it will be assumed that an active trade or business exists.

• Assume Foreign Corporation resides in a treaty country. If California Corporation is not considered a dependent agent, then it cannot establish PE for Foreign Corporation and therefore, the US sourced income will be exempt for federal purposes.

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• However, since California does not apply the provisions of US tax treaties to the extent they limit ECI, Foreign Corporation could still be partially included in the combined report even though this is not an issue for federal purposes.

• The next step is to determine if the royalty income is US sourced. If it is not considered US sourced income, then it will not be effectively connected income. As discussed earlier there are exceptions where foreign sourced income can be considered ECI but in order for these exceptions to apply, there must be an office or fixed place of business which is a material factor in the production of the income.

• Remember, that all US sourced income is considered effectively connected under the force of attraction rule if an active trade or business has been established in the US except FDAP. The force of attraction rule will apply for California purposes since the US tax treaty does not apply for California purposes. In this case the asset use test would be met and the royalty would be considered ECI.

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• Since this transactions involves software, Treas. Reg. §1.861-18 applies in determining the classification and sourcing rules. The first step is to properly classify the transaction as either a sale, service, lease, or licensing agreement.

• If not all substantial rights in the copyright have been transferred, the transaction will be classified as a license generating royalty income.

• The receipts from a licensing agreement are sourced to the location of the intangible asset or where the property is used. This is typically the location where the licensee has the right to use the intangible asset.

• In this example, the royalty income would be sourced to the United States, since that is where the intangible assets was used (where California Corporation has the right to re-produce and sell the software). The software is protected by a US copyright.

• This is therefore considered ECI for California purposes if the asset use or business activities test is met. If Foreign Corporation was affiliated with a unitary US corporation that filed a water’s-edge combined report, then Foreign Corporation would be partially included in the combined report to the extent of this ECI. Also, any gross effectively connected sales would be included in the sales factor.

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• What if Foreign was not affiliated with any unitary US Corporations? It does have ECI but would it be required to file a California return? A determination must be made if foreign Corporation has economic nexus under section 23101.

• A business entity is considered doing business in California for taxable years beginning on or after January 1, 2011, if it is actively engaging in any transaction for the purpose of financial or pecuniary gain or profit.

• In addition, if a business entity has a minimum amount of property, payroll or sales in California, then it will be considered to have economic nexus.

• In determining California sales for economic nexus purposes, the market based sourcing rules under R&TC §25136(b) apply for sales other than the sale of tangible personal property.

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• Assume the licensing agreement states that 60% of the royalty will be attributable to the trade name and trademark and 40% will be attributable to the Copyright.

• If the total royalties received from California Corporation are $1,000,000, then $400,000 will be attributable to the manufacturing intangible (Copyright) and $600,000 will be attributable to the marketing intangibles (trademark and trade name).

• The $400,000 will be sourced to California since that is where the intangible asset was used (reproduced). The $600,000 will be assigned to California based on a population percentage since we are assuming Foreign Corporation cannot determine the addresses of the ultimate customer (Regulation §25136-2).

• Assume the population percentage is 20%, then $120,000 will be assigned to California.

• Therefore, $520,000 in total will be assigned to California. Since this amount exceeds the sales threshold under section §23101, Foreign Corporation is considered to have economic nexus in California.

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• In the above example, the contract stipulated what portion of the royalty was attributable to the marketing and manufacturing intangibles. If the contract had not indicated the amount of fees to assign to each, then all of the fees would have been attributable to the marketing intangible and therefore, assigned to California based on the population percentage.

• Now that it has been established that Foreign Corporation has economic nexus in California, what next? Foreign Corporation will have a filing requirement in California and if it makes a water’s-edge election, then only its ECI will be included in the return (along with its effectively connected sales for apportionment factor purposes).

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20% US APPORTIONMENT RULE

• If a foreign corporation does not have any effectively connected income, it may still be included in the water’s-edge combined report if its US apportionment percentage is 20% or more.

• The California Revenue & Taxation Code §25110(a)(1)(B) states that any corporation (other than a bank) will be fully included in the water’s-edge combined report regardless of the place where it is incorporated if the average of its property, payroll and sales factors within the United States is 20% or more.

• In order to determine the average of a corporation’s property, payroll and sales factor within the US, the rules of each individual state should be applied. The average of the three factors for each state are then added to determine if the sum is 20% or more.

• If a foreign corporation does business in a state that has apportionment factor rules but does not actually file a return in that state, the rules for that state are nevertheless followed even though a return has not been filed.

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• If a foreign corporation does business in a state that does not impose a tax on income or assigns income on the basis of an apportionment formula that does not have each of the three factors, then the rules for California should be applied for any factor that the state does not use.

• Although a single sales factor formula is required for years beginning on or after January 1, 2013, the regulations still provide rules for determining the property and payroll factor.

• Should the rules under regulation section 25129 and 25132 apply in determining the property and payroll factors or should a single sales factor apply in determining the 20% rule?

• When California changed to a doubled weighted sales factor for years beginning on or after January 1, 1993, Legal Ruling 95-5 was issued to address questions raised by taxpayers regarding the calculation of the 20% U.S. apportionment factor rule.

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• The question was whether to apply the double weighted sales factor to the calculation or continue to apply the traditional three-factor formula.

• The Legal Ruling concluded that the traditional three-factor formula should continue to apply to the 20% rule even though the apportionment factor rules changed to a double weighted sales factor.

• Based on the analysis in Legal Ruling 95-5, it would appear that California will continue to apply the three-factor formula.

• If a foreign corporation does business in multiple states and these states do not have substantially uniform rules for calculating the property, payroll and sales factors, then the taxpayer may elect to compute the property, payroll and sales assignable to any individual state pursuant to California’s apportionment factor rules.

• If this election is made, does that mean that the single sales factor should apply or the traditional three-factor formula? Based on the analysis in Legal Ruling 95-5, it would appear that three-factor formula would apply.

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• In determining the sales factor, should the cost of performance rules apply or the market based sourcing rules?

• The market based sourcing rules apply to the single sales factor formula whereas the cost of performance rules typically apply to the three-factor formula. If California requires a three-factor formula in determining the 20% rule, shouldn’t the cost of performance rules apply? FTB could argue that under current law, the market based sourcing rules are required.

• A sale made by a foreign corporation to an affiliate, which is a member of the water’s-edge combined report, is not taken into account in computing the numerator or denominator of the sales factor.

• The 20% rule is applied each year to determine if a foreign corporation should be included in the water’s-edge combined report. Just because a foreign corporation is included in the combined report under the 20% rule in one year does not necessarily mean it will be included in all years.

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• The sourcing rules for cost of performance are much different than the market based sourcing rules. If the cost of performance rules are applied in determining the 20% rule, then you could end up using three different sourcing rules when preparing water’s-edge schedules. • Economic nexus & apportionment formula – market based sourcing rules• 20% rule – Cost of performance (If FTB decides to apply these rules)• ECI – US Sourcing rules

• Keep in mind that a foreign corporation could be included in the combined report based on the 20% US apportionment factor rule but not have any ECI. That is because the federal sourcing rules are used for determining ECI whereas California sourcing rules are applied in determining the 20% rule.

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• When would a foreign corporation be included in the combined report under the 20% rule but not the ECI rule?

• More than likely, a foreign corporation will not have any property or payroll in the US, therefore, the foreign corporation will need to have a 60% (or higher) US sales factor (dividend by 3 under 20% rule) in order to meet the 20% threshold.

• If a foreign corporation entered into a licensing agreement where it was determined that all substantial rights to a copyright were transferred, then the sourcing rules under Treas. Reg. §1.861-18 would provide a much different result then under regulation §25136-2.

• Under Treas. Reg. §1.861-18, the transfer would be considered a transfer of a copyright right and not a copyrighted article. Since all substantial rights are considered transferred, it would be treated as a sale of a copyright and not a licensing agreement. Therefore, the receipts would be sourced to the residence of seller which would be where the foreign corporation resides.

• If the copyright is used in the US (where the software is re-produced and sold), then under the 20% rule the receipts would be sourced in the US. This assumes that FTB would apply the market based sourcing rules under regulation §25136-2 and not the cost of performance rules.

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20% US APPORTIONMENT RULE - EXAMPLE 1

• Foreign Corp sells inventory to customers located in Japan, Arizona and Oregon. It has total sales of $100 million of which $20 million are sourced to Arizona, $10 million is sourced to Oregon and $20 million was made to a company located in Japan and is therefore foreign sourced. The other $50 million was made to its 100% owned US subsidiary located in California. The US Corp is considered unitary. US Corp files a water’s-edge return.

• Foreign Corp does not have any property or payroll in the US and has not established nexus in any of the 3 states.

• Does Foreign Corp meet the 20% US apportionment factor test to be fully included? Since the $50 million was made to a US affiliate included in the water’s-edge combined report, then that amount would be excluded from the calculation (both the numerator and denominator).

• Therefore the denominator would be $50 million. When applying the apportionment factor rules for Arizona, the sales factor would be 40% ($20 million over $50 million). Applying the apportionment factor rues for Oregon, the sales factor would be 20% ($10 million over $50 million).

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20% US APPORTIONMENT RULE - EXAMPLE 1

• By adding the apportionment percentages for each state that Foreign Corp does business in, you get a total of 60%.

• Since foreign Corp does not have any property or payroll in the US, then the property and payroll factors are 0%. You then take the total 60% and divide by three to get a 20% US apportionment factor. Since this amount is 20% or more, Foreign Corp will be fully included in the water’s-edge combined report.

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WATER’S-EDGE ELECTION

• Prior to the enactment of R&TC §25113, the water’s-edge election was made by contract under R&TC §25111. For years beginning on or after January 1, 2003, the election is now a statutory election.

• The election must be made on a timely filed original return.• The initial election must be for an 84-month period. This election must remain

in effect until terminated.• The election must be made by every taxpayer member of the water’s-edge

group. The election is made on form 100-WE. The water’s-edge tax return is form 100W.

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WATER’S-EDGE ELECTION – COMMON PARENT ELECTION

• If an election is made to file a group return (R-7), then form 100-WE must be attached for every taxpayer member unless a common parent election is made. If a common parent election is made, then each taxpayer member must be listed on the form 100-WE.

• A common parent election can be made in one of two ways. • If a common parent is an electing taxpayer it can make the common parent election. • If the common parent is not a taxpayer member, then an officer or other authorized agent of

the common parent must have authority to bind the other taxpayer members to an election. Another corporation in the group can make the common parent election if it has authority to bind the other taxpayer members to an election.

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WATER’S-EDGE ELECTION – SUBSTANTIAL PERFORMANCE

• Objective evidence can be met if a statement is attached to the timely filed original return indicating that a water’s-edge election was intended or if a water’s-edge form was attached to the return such as; FTB form 1115, 2416 or 2424.

• The water’s-edge manual section 3.1(d)(2) provides a list of five examples of objective evidence. At the end of the list it states; “Objective evidence is not necessarily limited to the items listed above. In order to meet the substantial performance test however, the objective evidence must be sufficient to support the conclusion that a water’s-edge election was intended.”

• Therefore, if the taxpayer did not attach a statement or a water’s-edge form, objective evidence can still exist. For example, if a taxpayer calculated the foreign investment interest offset, then that would indicate that a water’s-edge election was intended.

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WATER’S-EDGE ELECTION – SUBSTANTIAL PERFORMANCE

• The mere fact that all of the foreign corporations were excluded from the combined report is not objective evidence to support that a water’s-edge election was intended since it is possible that the taxpayer concluded that the foreign corporations were not unitary and were therefore excluded.

• If the water’s-edge group has a foreign parent and neither form 100W or 100-WE were filed, then it is much more difficult to determine if a water’s-edge election was intended since there are very few water’s-edge specific rules that apply to inbound groups (no forms).

• If however, a foreign corporation was partially included in the water’s-edge combined group to the extent of its effectively connected income and it also included its effectively connected sales in the apportionment factor, then that would be objective evidence to indicate that a water’s-edge election was intended.

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BDO KNOWLEDGE Webinar Series ‒ Water’s-Edge - Inbound Structure

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SPEAKER BIOGRAPHY


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BIOGRAPHY

CHRIS BERKNESSSenior Tax [email protected]: (562) 481-1032

Chris has over 25 years of experience in multistate/water’s-edge tax including ten years at the California Franchise Tax Board as their International Consultant. Over the last twenty years Chris has reviewed hundreds of water’s-edge cases involving some of the largest companies in the world including Shell Oil, Apple, Microsoft, Chevron, Pepsi, HP, Coca Cola and more.

While at the Franchise Tax Board, he worked directly with the audit staff to ensure that their cases were properly developed and that the law was correctly applied. In addition, he was responsible for providing water’s-edge training to both the audit and legal staff. Chris served as a member of the Water’s-Edge Technical Advisory Team, which was responsible for establishing water’s-edge policy and identifying issues that could result in a loss of revenue for the state of California.

BDO KNOWLEDGE Webinar Series ‒ Water’s-Edge - Inbound Structure

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BDO is the brand name for BDO USA, LLP, a U.S. professional services firm providing assurance, tax, financial advisory and consulting services to a wide range of publicly traded and privately held companies. For more than 100 years, BDO has provided quality service through the active involvement of experienced and committed professionals. The firm serves clients through 58 offices and more than 400 independent alliance firm locations nationwide. As an independent Member Firm of BDO International Limited, BDO serves multi-national clients through a global network of 1,328 offices in 152 countries.

BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. BDO is the brand name for the BDO network and for each of the BDO Member Firms. For more information please visit: www.bdo.com.

Material discussed is meant to provide general information and should not be acted on without professional advice tailored to your firm’s individual needs.

© 2015 BDO USA, LLP. All rights reserved.

water’s-edge – inbound structure · 2016-02-04 · bdo knowledge webinar series...

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