Interview with Mike Barbosa

We talked to Mike about his career path, and how international tax and international assignments have shaped his experiences.

A long time ago, I was a volunteer in the United States (US) Peace Corps, and had my first experience as an US expatriate teaching English language in Gyȍr and Nagykanizsa, Hungary. There is no doubt that experience was where I caught “the international bug” and wanderlust that has been a big part of my journey as a tax professional. Upon returning from Hungary with the Peace Corps, it felt Iike I was destined to join the US foreign service. However, during my time as a law student, I found myself charmed by the complexity and challenges of US taxation issues, so here I am.

During my career, I have had the opportunity to experience many sides (and geographies) of tax advisory services, first as part of a Washington DC-based in-house tax group of a large US telecommunication company that went spectacularly bust in 2001 , subsequently in a Big Four competitor firm doing International Tax and lateralled into Deloitte in 2006. Since that time, I had a great experience coming up in Deloitte’s Los Angeles International Tax Services practice. During then I also served as the US international tax expat to the USI–International Tax practice for 2 years in Hyderabad, Telangana, India. I have boomeranged out and back (the grass is not greener at the competitor’s side, I can attest to that), was entrusted with a leadership role for Denver, survived COVID-19, was seconded to a Swedish PE client, and for my latest stop, considered myself wildly fortunate to join the Singapore practice in Financial Services.

I have ventured in a lot of various sectors: worked with telecom, information technology, pharmaceutical, entertainment, aerospace, consumer products … all sorts of industries you might expect to encounter in a Southern California practice office. Value chain alignment is one of my favorite practice areas, its like a puzzle…putting all the value driving pieces of multinationals in the right places to get the right (and a reasonable) tax outcome. With value chain comes transfer pricing discussions, corporate structuring and reorganisations, they are all connected.

Most recently, I have retooled and focused on cross-border investment and financing transactions…ultimately most cross-border transactions both intra-enterprise and inter-enterprise, whether capital raising, Merger and Acquisitions, disposals, operating, etc. are essentially financing transactions.

What do you do when you are not “geeking-out” on tax items?

I love to travel! I love cameras but am at best a beginner level photographer. Seeing new places, having new experiences, and meeting new people energises me.

I have two grown kids, Martin, and Margaret, who are also world travelers and a yappy wirehaired fox terrier who has joined me in Singapore in April. I am also hopeful that my daughter will join me in Singapore during my time here so we can do some exploring together in Asia and Oceana. I am a backpacker and love nothing more than tramping around (preferably in the mountains) and pitching a tent.

Having been an Angelino for many years, cannot help but love the cinema and can bore you to death talking about movies you have never seen (but should!). I am a voracious reader of all sorts of things, not just tax.

From your perspective, what are some areas that Singapore and Asia Pacific (APAC) companies should be focusing on?

Implementation of Organisation for Economic Co-operation and Development (OECD) Pillar Two–it is a new world order and something that will hopefully address some of the tax imbalances and concerns of both the developed OECD economies and the developing world. Additionally, governance issues associated with investment platforms is an area that I suspect will be the target of focus in APAC, especially here in Singapore at the center of the investment industry for APAC.

Transfer pricing related to all the above…now that there seems to be a fix to the Base erosion and profit shifting (BEPS) problem, at least by making sure tax is paid somewhere, now the question will become is it being paid for income that was rightfully earned in any jurisdictions.

What are the US tax issues driving tax advisory services?

Harmonisation of US antideferral with Pillar Two minimum tax, income inclusion rules, and undertaxed profits rule. We have had an Internal rate of return for a long time in the US (subpart F and more recently Global intangible low-taxed income), so am happy to see that the world agrees with the US Treasury, but it is going to be fun integrating the US regime (which has some incompatibilities at present) into the global system.

For better or worse, Environmental, Social and Governance is a thing and will impact investment decisions and operations, and because everything is politicised, investments by state instrumentalities.

What else do you think is in-store for followers of the US tax melodrama?

Higher rates on individual income earned as capital gains…and do not hate me…reform of the treatment of carried interest income; more excise taxes on financial transactions…the US system is going to look a lot more like an European Union one and vice-versa. One way or another, revenue will have to increase to pay for benefits and programs available to US residents.

An inward focus on on-shoring manufacturing and intellectual property development—the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act was just the start.