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

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Corporate Changes
Corporate changes Tax change Post reform law Considerations Reduced Corporate Tax Rate & Move to Territorial Type System • Reduced 21 percent flat corporate federal income tax rate from 35 percent, generally effective Jan. 1, 2018 • Companies need to consider whether flow-through or corporate structure is most efficient • Investor make up? Net Operating Loss (NOL) rules • Limits NOL deduction to 80 percent of taxable income for NOLs arising in years beginning after Dec. 31, 2017 • Eliminates NOL carrybacks for NOLs arising in years ending after Dec. 31, 2017 • NOLs generally carried forward indefinitely if they arise in years ending after Dec. 31, 2017 • Fiscal year taxpayers with years ending after Dec. 31, 2017 cannot carryback losses • Limited impact on state NOLs as many states have their own NOL deduction provisions 5
Page 1 and 2: Helping with tax challenges whereve
Page 3: Overview BEPS Global Tax Reform US
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 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