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

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International tax provisions: GILTI Minimum Tax Tax change Post reform law Considerations Global Intangible Low Taxed Income (GILTI) (effective for tax years beginning after Dec. 31, 2017) • Targeted at foreign corporations that earn a high rate of return on their intangible assets • Much broader than intangible holding companies • All industries • Calculates tax on amount over net deemed tangible income • GILTI applies to any CFC • C corporations receive a deduction against GILTI equal to 50 percent • Expectation is that many CFCs will be subject to GILTI • Effectively a 10.5 percent minimum tax CFC is owned by a domestic C Corp • Eligible for partial foreign tax credit offset • New diligence item 32
GILTI Example Calculation GILTI Calculation QBAI 200 Routine % of return – 10% 10% Net deemed tangible return 20 Net CFC tested income 120 Net deemed tangible return (20) GILTI 100 US Tax Calculation GILTI 100 Allowed deduction (50% of GILTI) 50 US Taxable Income 50 Tax Rate 21% US Tax (A) 10.5 Qualified business asset investment (“QBAI”): Equals the CFC’s average aggregate adjusted bases for specified tangible property. Routine return is 10% x QBAI - Net Interest Expense Interest expense less allocable interest income taken into account in determining net tested income. Net CFC tested income: The excess (if any) of the aggregate tested income of each CFC less the aggregate tested loss of each CFC. Example assumes no foreign taxes paid – generally 80% of foreign taxes paid (subject to limitations) may be available to offset US taxes paid on GILTI
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 and 22: Anti-hybrid provisions
Page 23 and 24: US Hybrid Counteraction The Act den
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: Global Intangible Low Taxed Income
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

2. Int&#039;l Tax Update Significant Developments in the Global Tax System - Andrew Seidler

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