2. Int'l Tax Update Significant Developments in the Global Tax System - Andrew Seidler

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US Hybrid Rules A “hybrid entity” is any entity that is: • Fiscally transparent for US tax purposes but not transparent under foreign law, or • Fiscally transparent for foreign law purposes, but not transparent for US tax purposes. A “hybrid transaction” is any transaction, series of transactions, agreement, or instrument • treated as interest or royalties for US federal tax purposes • but not treated as interest or royalties by the country in which the related party is resident. US hybrid entity Acquisition US UK Holdco Non-US Affiliate UK Not a US hybrid transaction Interest Interest group relief
US Hybrid Counteraction The Act denies a deduction for any disqualified related party amount paid or accrued pursuant to a hybrid transaction or by or to a hybrid entity. US hybrid entity US Disqualified related party amount Interest A “disqualified related party amount” is any interest or royalty paid to a related party where the related party • does not include the payment in its income in the country in which it is a resident or • is allowed a deduction with respect to the amount in the country in which it is a resident. Acquisition UK Holdco Non-US Affiliate UK Interest group relief Treasury Regulations expected.
Page 1 and 2: Helping with tax challenges whereve
Page 3 and 4: Overview BEPS Global Tax Reform US
Page 5 and 6: Corporate changes Tax change Post r
Page 7 and 8: Corporate changes Tax change Post r
Page 9 and 10: UK Planning Considerations: NOL Lim
Page 11 and 12: Withholding Taxes After Brexit •
Page 13 and 14: Withholding Taxes and the Digital E
Page 15 and 16: Common Consolidated Corporate Tax B
Page 17 and 18: Digital Economy Interim Measure Exa
Page 19 and 20: BEPS Measures: Anti-hybrid rules In
Page 21: Anti-hybrid provisions
Page 25 and 26: UK approach compared to US Type Mis
Page 27 and 28: Interest Limitation
Page 29 and 30: Interest deduction - comparison wit
Page 31 and 32: Global Intangible Low Taxed Income
Page 33 and 34: GILTI Example Calculation GILTI Cal
Page 35 and 36: Foreign Derived Intangible Income F
Page 37 and 38: FDII Example US Corp US sales $500
Page 39 and 40: FDII Example Step 4: Determine Rati
Page 41 and 42: UK Planning Considerations: FDII Pu
Page 43 and 44: BEAT - Base Erosion Anti-Abuse Tax
Page 45 and 46: UK Planning Considerations: BEAT In
Page 47 and 48: Brexit Monitor Visit https://www.rs
Page 49: THANK YOU

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2. Int'l Tax Update Significant Developments in the Global Tax System - Andrew Seidler