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

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FDII Example Summary Taxable income 1,100.0 FDII Deduction 262.5 Adjusted Taxable Income 837.5 Tax Rate 21.0% Total Tax 175.9 U.S. Corp. ETR 15.989%
UK Planning Considerations: FDII Purpose is to encourage groups to either bring IP back to the US or to leave it in the US. Beneficial tax rate (13.125%) applies to US sales to foreign customers. Does not apply to income taxed on a C Corporation in the US from disregarded subsidiaries. IP Co US Ireland Fin Co UK EU EUEU
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 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: FDII Example Step 4: Determine Rati
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