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

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International tax provisions: Repatriation and DRD Tax Change Post Reform Law Considerations One-time deemed repatriation tax on foreign deferred earnings (effective for tax years beginning before January 1, 2018) • Foreign deferred earnings are taxed at 15.5 or 8 percent based on balance sheet attributes (cash & cash equivalents vs. non-cash assets, respectively). • Election to defer payment over 8 years • Determine applicability at portfolio and owner level • Significant diligence item as well as cash flow concern • Need to understand E&P on all impacted companies • Many states will treat the repatriation as Subpart F income subject to full or partial dividend received deduction Dividend Received Deduction/ Participation Exemption (effective for distributions made after Dec. 31, 2017) • Certain foreign dividends non-taxable in the US • Certain gains on sale of foreign subsidiaries will not be subject to U.S. federal income tax • Applicable to C-Corporations with foreign corporation(s) • Corporate structure may be benefit due to participation exemptions • How significant are foreign earnings? 6
Corporate changes Tax change Post reform law Considerations Immediate Expensing – Bonus Depreciation • 100 percent bonus depreciation through 2022, then phased out through 2026 • Applies to new and used property acquired and retroactive to assets placed in service after Sept. 27, 2017 • Adds more importance to purchase price allocation agreements • Asset deals are even more attractive • States may not conform • Immediate expensing benefit is reduced to the extent it generates an NOL Corporate Alternative Minimum Tax (AMT) & AMT Credit • Repeals corporate AMT for tax years beginning after Dec. 31, 2017 • Credits can be refundable • Refundable credit is an unexpected benefit 7
Page 1 and 2: Helping with tax challenges whereve
Page 3 and 4: Overview BEPS Global Tax Reform US
Page 5: 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