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

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Base Erosion Anti-abuse Tax BEAT
BEAT – Base Erosion Anti-Abuse Tax Tax change Post reform law Considerations 43 Base Erosion and Anti Abuse Tax (BEAT) (effective for tax years beginning after Dec. 31, 2017) • 10% minimum tax on U.S. corporations (5% for 2018). • Applies where 10% of ‘modified taxable income’ (MTI) exceeds regular tax. • MTI is taxable income without regard to base erosion tax benefit (i.e., no deduction for base erosion payments). • Base erosion payments include any deductible amount paid/accrued to a foreign related party. • Includes payments for depreciable property or insurance payment. • Excludes items that reduce gross receipts (like cost of goods sold). • Threshold for related party status 25 percent vote or value. BEAT applies to U.S. corporations not treated as flow-through (e.g. S corps, REITS, RICs). USD 500 million of domestic gross receipts if base erosion percentage is 3 percent or higher. Members of U.S. consolidated group are treated as single corporation.
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 and 40: FDII Example Step 4: Determine Rati
Page 41: UK Planning Considerations: FDII Pu
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